Community versus Outsiders

Palo Alto and Menlo Park sit on either side of San Francisquito Creek, in two counties, with two city halls about two miles apart. Each is a somewhere: a city with its own streets, its own quarrels and its own long memory of who said what at which planning commission meeting. On Tuesday both chose members of their city councils, and the races in the two cities turned on the same difference between candidates. On one side stood people whose standing came from years in a neighborhood’s own institutions, the ones Palo Altans call residentialists. On the other stood candidates whose platforms, money and endorsements came largely from a regional and state program for housing, the program whose activists call themselves YIMBYs, for “yes in my back yard.” Mostly the neighbors won.

Palo Alto

Palo Alto chose three council members from a field of eight. As of Wednesday morning the count had Bryna Chang, the chair of the Planning and Transportation Commission, first with 8,010 votes, 23.8 percent; Mayor Vicki Veenker second with 7,424; and Councilman Ed Lauing 28 votes behind her with 7,396. Yu “Yudy” Deng, a member of the Parks and Recreation Commission, was fourth with 4,605, 13.7 percent. Raymond Goins, running with the Democratic Socialists of America, had 5.3 percent. On the same ballot a rent-control measure, Measure E, was losing. The results won’t be certified until December 3.

Deng raised $182,131, more than twice what Chang raised and, by the Daily Post’s count, more than any Palo Alto council candidate before her. Chang pointed out before the election that 102 of Deng’s 157 donations came from outside the city, among them maximum contributions from a statewide civic committee and from executives in other towns, and $2,000 from State Treasurer Fiona Ma. By the end of June, 26 of Chang’s 28 donations had come from Palo Alto. Deng lives in Palo Alto, but she came to its civic life recently. This was her first race, and the council put her on the parks commission in 2024, a year after passing her over for it. At one of her campaign events Santa Clara County Supervisor Margaret Abe-Koga called the criticism of her out-of-town money “a little tinge of racism.” Goins said on election night that “this election was bought.” The count says otherwise: the candidate with the most money finished a distant fourth.

Chang and Lauing had campaigned almost as a pair, each giving $500 to the other’s campaign, on a platform of neighborhood character, public safety, retail on California Avenue and slower growth. Deng’s platform put streamlined housing approval first. “We both think the voters want candidates that are very experienced in Palo Alto,” Lauing said on election night, standing beside Chang.

Menlo Park

Menlo Park elects its council by district, and three of five seats were on the ballot. The issue under all three was a plan in the city’s state-mandated housing element to put more than 300 affordable units on three city-owned parking lots downtown, a proposal that has packed council meetings for more than two years. Residents organized as Save Downtown Menlo collected signatures for Measure P, which would require a public vote before any of the eight downtown lots could be repurposed. The council sent it to the ballot unanimously.

In District 4, downtown and central Menlo Park, the seat was open. Laura Melahn, one of the founders of the Downtown Menlo Fund, offered an amendment to the housing element that would put the affordable units elsewhere, on the former SRI International and U.S. Geological Survey campuses, and Save Downtown Menlo backed it. Charlotte Reed supported building on the lots, opposed Measure P and argued that the state would penalize the city if it walked away from its plan. Melahn led 968 to 552, almost two to one.

In District 2, the Willows, the Flood Triangle and Lorelei Manor, Councilman Drew Combs is seeking a third term. He has been the council’s lone dissenting vote on many decisions over eight years, was the first council member to oppose 80 Willow, a project with a tower of up to 39 stories on the old Sunset Magazine campus, and proposed starting downtown housing on one parking lot instead of several. His challenger, Vamsi Velagapudi, a former consultant with McKinsey and an engineer at Google, Cisco and HP, moved to Menlo Park eight years ago and to District 2 about a year ago, and supports the parking-lot plan. Combs led 565 to 549 on election night. By Wednesday morning Velagapudi led 721 to 712, nine votes, with ballots still arriving. California has no automatic recount. Any voter may ask for one between the thirty-first and thirty-sixth day after the election, and pay for it.

Measure P itself trailed in the first count, 3,474 to 3,799, 47.8 percent. That is nearly ten points better than either of the last two development initiatives Menlo Park voters turned down, Measure V in 2022 and Measure M in 2014, each of which won about 38 percent.

District 1, Belle Haven, went the other way, and it shows what the thread is and what it isn’t. Wonman Lee, a parks commissioner who favors more housing, led James Rohr, a Belle Haven volunteer and Army veteran, 510 to 175. Belle Haven is the neighborhood east of Highway 101 where Meta built its campus and then paused Willow Village, the project that was to give the district a commercial center. Both candidates wanted a grocery store first. Lee argued that more housing is what would bring one. In Belle Haven, more building is what the neighborhood itself is asking for, and it chose the candidate who said so. A residentialist isn’t someone who opposes housing. It’s someone who thinks the neighborhood that lives with a building should have the largest say in whether it goes up.

The common thread

Across the two cities, the differences between contestants line up with some consistency. The residentialist candidates had long records in their cities’ own commissions, councils, and downtown and neighborhood groups, raised most of their money at home, and argued about specific parcels: the Coronet Motel site, the Mollie Stone’s site, a parking plaza behind Santa Cruz Avenue. The candidates on the other side tended to be newer to local civic life, drew more of their money and endorsements from outside, and argued from the state’s numbers, the housing element, the regional allocation and the penalty for falling short. Their program was largely written in Sacramento, and they proposed to carry it out.

The YIMBY movement isn’t wrong that California needs more housing. Pro-Housing, Not Pro-(or Anti-) Development argued for more of it, and The Fairest Tax of All argued that affordable housing is a land problem before it’s a building problem. What the movement has done, though, is move the decision. Its most effective work in the past decade hasn’t been persuading neighbors. It has been persuading the Legislature to decide for them, and then running candidates in the cities to carry out what the Legislature decided. A council member elected on that platform answers in practice to the state program first and to the street second. That is what makes such a candidate an outsider, whatever her address.

More housing isn’t all the program asks for. YIMBY as organized today is a set of methods, and the methods produce a particular kind of housing in a particular place: midrise apartment blocks packed within a walk of a rail station, with few or no parking spaces, on the premise that residents will ride a train to a central job. SB 79 grants its extra height and density only near transit stops, and AB 2097, signed in 2022, bars cities, with narrow exceptions, from setting minimum parking requirements within half a mile of one. Together they engineer daily life as much as they supply housing, choosing for a household where it lives, how it travels to work and what its street looks like.

That pattern fit a factory economy. In the early twentieth century a worker had to be at a mill or an office tower at the same hour as several thousand others, and a city built on rail lines running into a center was how they got there. Much of the Peninsula’s work no longer runs that way. An engineer at a Menlo Park firm may spend three days a week in a home office and two in a building off the freeway, and a family whose work arrives over a laptop needs a spare room and a yard more than a platform a quarter mile off. Even after electrification, Caltrain carries about four-fifths of the riders it did before the pandemic, while its weekend trains, which nobody’s employer schedules, run at about half again their old level, and the state zones the Peninsula as though everyone still rode it to work. A pattern of settlement that people would choose follows their work and their land, the creek, the hills and the distances between towns, and one the state imposes against both has to be held in place by fines and court orders. Social liberty stands for the inverse: communities finding their own forms, and government following what grows on the ground instead of using its power to remake a society to fit a plan.

What a community knows

Why it should matter who decides, as long as the housing gets built, is a question Californians used to be able to answer, and most have forgotten the answer. It has several parts, and they reinforce one another.

The first is knowledge. A Palo Alto planning commissioner who has sat through four years of hearings knows which intersection backs up at school pickup, which creek-side block floods in a wet February, which shopping street is holding on by a few tenants and which owner has let a lot sit empty for a decade. Chang ran on neighborhood traffic management because she had spent years on exactly that. Melahn’s alternative to the parking-lot plan came from knowing that the old SRI International and Geological Survey campuses were about to change hands. Friedrich Hayek called this “the knowledge of the particular circumstances of time and place,” and argued in 1945 that it can’t be gathered into a central office, because it exists only scattered among the people on the spot. A state housing allocation is a number per city. It knows nothing about the creek. Competent local policy depends on knowledge of that kind, and a council that answers to the people who hold it can use it, where a council carrying out Sacramento’s numbers has to set it aside.

The second is that rules work better when the people who live under them help make them. Elinor Ostrom spent her career studying communities that had managed shared land, water and fisheries for generations, Swiss alpine pastures, Japanese village forests, Spanish irrigation districts, and found that the long-lasting ones shared a few traits. Two were that most of the people affected by the rules could take part in changing them, and that outside authorities didn’t overrule the institutions the community had built. Where a distant government replaced local rules with its own, the commons often fell apart, because the people who had kept them up no longer had reason to. She won the Nobel prize in economics for the work in 2009. California’s housing law, with its strike force and its monthly fines, breaks both of her conditions at once.

The third is that having a say makes people happier, apart from what they get. The economists Bruno Frey and Alois Stutzer compared the twenty-six Swiss cantons, where citizens’ rights to initiatives and referendums, and the independence of the communes, vary a great deal from one canton to the next. People in cantons with more direct democracy and more local autonomy reported higher satisfaction with their lives, after accounting for income, age, education and the rest. Part of the gain went to foreigners living there too, who couldn’t vote, which pointed to better policy. A larger part went only to citizens, which pointed to the value of taking part itself, what Frey and Stutzer called procedural utility. Switzerland governs itself through more than two thousand communes, most of which set their own tax rates, and it ranks near the top of the world’s surveys of life satisfaction year after year. A happy life for its citizens isn’t the same thing as a good outcome delivered to them.

The fourth is choice among places. Charles Tiebout argued in 1956 that when many small jurisdictions each offer their own mix of taxes, services and rules, people can sort themselves into the ones that suit them, and the jurisdictions learn from one another’s successes and failures. A state rule applied to every city alike ends the experiment. If Palo Alto and Menlo Park are wrong about their downtowns, a neighboring city doing it differently is how anyone would find out.

None of this used to belong to one side. Thomas Jefferson wanted every county in Virginia divided into “ward republics” small enough for every man to attend, and wrote to Joseph Cabell in 1816 that where every citizen shares in governing his ward, “he will let the heart be torn out of his body sooner than his power be wrested from him by a Caesar or a Bonaparte.” Alexis de Tocqueville, visiting New England’s towns in the 1830s, wrote that “town meetings are to liberty what primary schools are to science.” California wrote home rule into its constitution in 1879 and widened it to “municipal affairs” in 1896 and again in 1914, in the decades when the Legislature answered to the Southern Pacific Railroad and cities wanted a government the railroad couldn’t buy wholesale. The young radicals of the Port Huron Statement in 1962 asked for a “participatory democracy” in which each person would “share in those social decisions determining the quality and direction of his life.” And the patron saint of today’s urbanists, Jane Jacobs, made her name leading the residents of Greenwich Village against Robert Moses, a state-backed planner who knew better than they did what their neighborhood needed and planned an expressway through it. She was, by any definition used in Palo Alto this fall, a residentialist.

The Municipality Against the State traced the longer history of cities standing between their people and a larger power. What Palo Alto and Menlo Park voted on Tuesday was a small instance of it: whether the people who know the creek and the parking plaza will keep the last word on them.

The party’s picks

The Santa Clara County Democratic Party endorsed two candidates for Palo Alto’s three seats, Veenker and Deng, and passed over Chang and Lauing. Veenker, the incumbent more willing to approve larger and denser projects, held her seat by 28 votes. Deng lost by nearly 3,000.

That is close to the party’s record in Palo Alto. In 2020 it endorsed Raven Malone, Steven Lee and Cari Templeton; none won. In 2022 it endorsed Veenker and Julie Lythcott-Haims, and both won. In 2024 it backed George Lu, Katie Causey and Templeton again, a pro-growth slate, and only Lu won. Add this year and the party’s picks have won four of ten. The local chapter of the Sierra Club, which tends to back the residentialists and endorsed Combs in Menlo Park, has won about three of every four in Palo Alto.

In a city where nearly every candidate is a Democrat and most hold liberal views on most things, the party isn’t choosing between parties. It is choosing between factions of itself, and the faction it keeps choosing is the one that agrees with the state on land.

An outsider law about land

Land is about as local as anything a government touches. A parcel can’t move; its value comes from the street it sits on, the school down the block, the trees and the noise and the neighbors. Yet the laws that now decide what can be built on a Palo Alto or Menlo Park parcel are increasingly written in Sacramento.

Senate Bill 79, carried by Sen. Scott Wiener and signed by Gov. Gavin Newsom in October 2025, took effect July 1. Near qualifying transit stations it sets floors on height and density that override local zoning: up to 75 feet within a quarter mile of a Caltrain station, up to 65 within a half mile. Palo Alto has three such stations in or next to it, and Menlo Park’s station sits at the edge of the downtown whose parking lots it was fighting over. Palo Alto opposed the bill. On June 15 its council voted to use the law’s one concession, a temporary cap at half its standards and an exemption for locally listed historic buildings, until January 2032. The ordinance couldn’t take effect for thirty days. In the two weeks between the state law and the local rule, the city received nine preliminary applications for 341 units, among them a six-story building on California Avenue and another on the Coronet Motel site on El Camino Real. Councilman Pat Burt proposed an emergency ordinance to close the window; Veenker, Vice Mayor Greer Stone and Lythcott-Haims declined to call it an emergency. Meanwhile a 382-unit project on the Mollie Stone’s site on California Avenue, with a tower of seventeen stories, filed in late 2023 under the state’s builder’s remedy, is still moving through review.

The builder’s remedy is the stick behind Menlo Park’s argument too. A city whose housing element the state decertifies loses much of its power to deny projects that meet the remedy’s terms, and that threat was the main case against Measure P. Whether Menlo Park’s downtown gets housing on its parking lots was put to the voters, but the shape of the choice they were given, and the penalty for choosing wrong, came from the state.

A top-down zoning mandate is an odd tool for a land problem. It acts on the height of buildings and leaves the rent on land where it was, captured by whoever held the parcel near the station on the day the law passed. A city that taxed land value could push its own idle and underused parcels toward housing without a single floor being dictated from four hours away. The state chose the outsider’s tool, and in Palo Alto’s two-week gap its first beneficiaries were the owners quickest to file.

The charter cities

California gave its cities a way to govern themselves well over a century ago. Article XI, section 5 of the state constitution lets a city adopt a charter and, in “municipal affairs,” make and enforce its own laws even where they conflict with the state’s. Palo Alto has been a charter city since 1909. Menlo Park is a general-law city, governed by the state’s codes from the start, and holds even less ground of its own.

The doctrine has a seam in it. The courts have held that where a matter is of “statewide concern,” state law prevails even in a charter city, and the Legislature has learned to write the seam into its bills. SB 9, which since 2022 has let owners split single-family lots and put up to four units on them, declares housing a matter of statewide concern and not a municipal affair. So does SB 79, and so do most of the housing bills in between. In 2024 a Los Angeles Superior Court judge held that SB 9 couldn’t be applied to five charter cities, Redondo Beach, Carson, Del Mar, Torrance and Whittier, because the bill didn’t do what its declaration claimed. The state appealed, and in November 2025 an appellate panel sent the case back after the Legislature amended the law.

Where a declaration doesn’t settle a dispute, the state now sends its lawyers. In 2021 Attorney General Rob Bonta set up a Housing Strike Force, and the Department of Housing and Community Development added a Housing Accountability Unit the next year. Huntington Beach, a charter city, refused to plan for its regional housing allocation, and the state sued it in March 2023. The trial court found against the city in May 2024. That September the governor signed SB 1037, another Wiener bill, which set penalties of at least $10,000 a month for a city without a compliant housing element and $50,000 a month after a missed court deadline. In 2025 the Fourth District Court of Appeal held that the city’s charter didn’t shield it, since housing element law is “reasonably related to a statewide concern,” and ordered limits on its power to issue permits, zone and subdivide land until it complied. The state Supreme Court declined to hear the city’s appeal. In May 2026 a San Diego judge ordered Huntington Beach to pay $160,000 in back penalties and $50,000 a month from June. The governor’s office announced the ruling under the headline “NIMBYs be warned.” NIMBY, “not in my back yard,” is a pejorative, and the YIMBY movement has made it the name for anyone who opposes its program. When a governor puts it in an official headline about a lawsuit his own administration brought, the state has stopped pretending to be a referee. It’s a party to the dispute, and it’s using that party’s word for the other side.

Huntington Beach is the loudest case, and there are others: - Elk Grove, near Sacramento, turned down Oak Rose, a supportive-housing project, in 2022. It ended up paying the developer about $10 million and giving city land away at no cost to settle with the developer and the state. - La Cañada Flintridge rejected a builder’s remedy project of 80 units, and the state joined the suit. A judge held in 2024 that the city had broken state law. - Norwalk passed a moratorium on new homeless shelters in 2024. The state decertified its housing element, cutting off state money and its power to deny certain projects, then sued. Norwalk repealed the ban in a 2025 settlement. - Woodside declared the whole town mountain-lion habitat to slow SB 9 lot splits, and backed down after a warning letter. - Five more cities were sued in July 2026: Calexico, Costa Mesa, Turlock, Ridgecrest, and Half Moon Bay, twenty miles over the hills from Menlo Park.

This is a state bullying its communities. The tools are the same each time. The state cuts off the city’s money, fines it by the month, strips its power to issue permits and zone its own land, and calls its residents NIMBYs in a press release. The same few officeholders wrote the law, set the penalty, judged the city’s plan and brought the suit, so no step of the process is in neutral hands. A city council answers to its residents every week, in public, a few blocks from where they live. The Legislature that sets the terms answers to them through districts the party has held for a generation, and its opponents are summoned to court in a county they’ve never been to. Each of these cities was a community with its own reasons, good or bad, for the choice it made. The state didn’t argue with those reasons. It overpowered them.

The result is that what to build on a parcel, the most municipal of municipal affairs, has been redefined as a state concern one bill at a time, and the home rule the charter promised now covers less of the ground it was written for. A council’s power to decide the use of its own land, and with it much of the shape of its local economy, has been moving upward to the Legislature for a decade, and each move arrives with a label saying it isn’t a municipal affair.

Total control

The California Democratic Party is no faction in the Legislature. It is the Legislature. Democrats hold supermajorities of more than two-thirds in both houses and every statewide office, and they make up about 45 percent of registered voters to the Republicans’ 25. The fastest-growing group is voters with no party preference, nearly 23 percent statewide and close to 28 percent in Santa Clara County. Under the top-two primary, many general elections offer two Democrats, and a seat that never faces a real opponent from outside the party answers mostly to the party.

A government in that position can stretch the law a long way from what the people who live under it want, because nothing in its own structure pulls it back. The Legislature doesn’t need a single opposition vote to pass a bill, override a veto, put a constitutional amendment on the ballot or adopt a budget. SB 79 is one example of the stretch: a land-use law for a whole state, passed over the objections of many of the cities it governs, Palo Alto among them.

The other check a free people relies on is the press, and there the hold is informal but nearly as complete. No one in Sacramento owns a newspaper. The state’s largest outlets don’t need to be owned to share the majority’s frame: their editorial boards mostly argue inside the Democratic coalition, over how fast and how far, rather than about whether the state should be zoning cities at all, and the reporters who once covered the Capitol full time have thinned along with the newsrooms that paid them. A law like SB 79 arrives in most Californians’ feeds already described as the housing bill, its opponents already described as NIMBYs. Tragedy of the Commons Word traced how repetition sets what goes without saying. When the party that writes the laws and the outlets that describe them share one vocabulary, the checks that remain are the courts, the initiative and the cities, and the cities are the only one of those that meets every week in public, a few blocks from the people it answers to.

The endorsement question has a sharper one. In June 1986 California voters approved Proposition 49, which wrote into the state constitution that no political party or party central committee may endorse, support or oppose a candidate for nonpartisan office. City offices had been nonpartisan since the Progressive Era; the voters wanted the parties kept out of them. The party sued, and in 1996 a federal court in California Democratic Party v. Lungren held the ban a violation of the First Amendment. The party has the right to endorse in a city race. The people of California said plainly that they would rather it didn’t, and the party does it anyway.

Why a single party should stay out

In a two-party place a local party endorsement is a signal among rivals. In a one-party state it is something else, for several reasons that reinforce one another.

It hides the real disagreement. Nearly everyone on the Palo Alto ballot was a Democrat. The choice in front of voters was between residentialists and the YIMBY program, between candidates who wanted the council to resist the state and candidates who wanted it to carry the state’s program out faster. A party endorsement dresses one side of an argument among neighbors as the party’s position, and voters who disagree are cast as disloyal to a party they mostly belong to. Tragedy of the Commons Word made the same point about a word stretched across a party’s factions: the stretch makes the factions hard to see.

It turns a council seat upward. A council member endorsed by the county committee owes something to the county committee, and the committee is part of the same organization that writes the state’s land laws. A city council is one of the few bodies left in California that can tell Sacramento no. A party that already holds Sacramento and fills the council seats with its picks has removed one of the last checks on itself.

It spends the label. Each time the party endorses in Palo Alto and loses, voters learn to discount the endorsement, and the discount doesn’t stay local. Four wins in ten is a record that tells residents what the party knows about their city. The label is a commons too, and the party is grazing its own.

And it treats the community as a precinct. California’s political temper, its zeitgeist, assumes the dominant party and the community are the same thing, so that the party’s choice in a local race is simply the community’s choice made early. Tuesday’s count says they are not the same. Palo Alto voters, overwhelmingly Democrats themselves, chose two candidates the party passed over and gave the one it backed most heavily less than a seventh of the vote.

Deng took her loss gracefully and said she would put her energy into raising money for the Cubberley Community Center, which the city’s half-cent sales tax, Measure J, would help buy if its lead of a few hundred votes holds. In Menlo Park the late mail ballots will decide District 2 and Measure P, and a recount, if anyone asks for one, will be paid for by whoever asks. Whatever happens to either count, the people who will decide what gets built near the California Avenue station and on the parking plazas behind Santa Cruz Avenue next year are neighbors whose phone numbers half of each city already has.

---

A note on how this piece was written: every argument, source, and structural decision in this piece is ours. We chose the examples, worked out the logic connecting them, and directed what each paragraph needed to say. The sentences themselves were drafted with AI assistance from that outline and then edited by hand. We’d rather say that plainly than have a reader guess at it.

Sources: Palo Alto Daily Post, Money can’t buy you love, or a seat on City Council, Seesaw race for Menlo Park council seat, Early election results in local races, Santa Clara County Democrats endorsements include Deng, Veenker, Henigin and Dailey, Out-of-town money floods council race, New faces join Palo Alto council, school board races, Three developers have taken advantage of two-week gap in housing law, and New law will allow 7-story buildings near Caltrain stations; Palo Alto Online, Chang, Lauing, Veenker poised to prevail in Palo Alto council race and When it comes to Palo Alto council endorsements, not all carry equal weight; The Almanac, Menlo Park’s Measure P narrowly trails in early returns, Laura Melahn takes a commanding lead for Menlo Park City Council District 4, Candidates for Menlo Park council spar over city’s future in election forum, Menlo Park candidate pitches alternate housing plan, Council races at a glance, and candidate profiles of Vamsi Velagapudi, Laura Melahn and Charlotte Reed; Local News Matters, Menlo Park measure limiting housing on downtown parking lots heads to next year’s ballot; Sierra Club Loma Prieta Chapter, November 3, 2026 endorsements; KQED, 2026 Santa Clara County election results; Santa Clara County Democratic Party, 2026 Endorsements; City of Palo Alto, Status of the City’s Temporary SB 79 Implementation Regulations and letter opposing SB 79; San José Spotlight, Palo Alto may lead efforts to restrict ‘builder’s remedy’; California Department of Housing and Community Development, AB 2097 technical assistance on minimum parking requirements near transit; Caltrain, Caltrain Ridership Remains Strong Through FY26 (July 20, 2026); California Constitution, Article XI, section 5, and Article II, section 6; KQED, Judge rules California split-lot housing law unconstitutional; California Attorney General, notice of appeal on SB 9; California Secretary of State, 60-day report of registration for the June 2, 2026 primary; Ballotpedia, California Proposition 49 (June 1986); California Democratic Party v. Lungren, 919 F. Supp. 1397 (N.D. Cal. 1996); Office of the Governor, NIMBYs be warned: Court orders Huntington Beach to pay up for repeated violations of housing law; Courthouse News, Huntington Beach can’t dodge affordable housing mandate; Davis Vanguard, Huntington Beach faces court-ordered remedies for violating housing law; California Attorney General, Settlement with City of Norwalk over unlawful housing ban; GV Wire, California settles lawsuit with Sacramento suburb over affordable housing project; The Real Deal, Newsom slams La Cañada Flintridge in housing case; ABC10, Attorney General Bonta creates a strike force; KALW, Bonta announces lawsuit against five California cities; Friedrich Hayek, “The Use of Knowledge in Society,” American Economic Review 35 (1945); Elinor Ostrom, Governing the Commons: The Evolution of Institutions for Collective Action (1990); Bruno S. Frey and Alois Stutzer, “Happiness, Economy and Institutions,” Economic Journal 110 (2000), and “Beyond Outcomes: Measuring Procedural Utility,” Oxford Economic Papers 57 (2005); Charles Tiebout, “A Pure Theory of Local Expenditures,” Journal of Political Economy 64 (1956); Thomas Jefferson to Joseph C. Cabell, February 2, 1816; Alexis de Tocqueville, Democracy in America, vol. 1 (1835); Students for a Democratic Society, The Port Huron Statement (1962); Jane Jacobs, The Death and Life of Great American Cities (1961); Pew Research Center, Statehouse reporters (2022).