When the Federal Constitution was submitted for ratification, many of the conventions in the several States, dissatisfied with certain features and more often with omissions in, the new instrument, offered amendments. These were numerous and varied, and some were later adopted. In New York and Rhode Island the conventions offered an amendment for the recall of United States Senators at the will of the Legislature, and the substitution of others. In 1803 and again in 1806, the Virginia Legislature passed resolutions in support of such amendment for recall. A revival and much broader application of the principle has lately been seen. In 1903 the city of Los Angeles, California, amended its charter by popular vote, and in addition to the initiative and referendum, it placed in the people’s arsenal another powerful weapon—the recall. A few words in the charter clearly define the recall. In the special election in September 1904, the councilman whose course in voting for two certain ordinances was not approved by his ward, was defeated by another candidate. The incumbent then petitioned the Supreme Court for a writ of mandamus to compel the rest of the council and city government generally to recognize him for the remainder of his term. Without deciding the point, the court assumed the validity of the recall amendment, but sustained the petitioner on the ground that the procedure in calling the special election was not quite regular. Even on this point, Chief Justice Beatty dissented. In an inferior court, the matter had come up in another form, and Judge Ostler decided against the incumbent, holding that the recall amendment is not obnoxious to either the State or Federal constitution, that it was not necessary to make charges in the petition for election, but simply to make statements of reasons to enlighten the public; that the officer had no property in the office nor vested right to hold to the end of his term; that it was no contract, but a mere agency, terminable at any time by the principal, the sovereign people.