In a mixed portent for the future, California voters recently closed the first act in what is likely to be a long-running power play. On June 8th, California voted, by a two-to-one margin, against a ballot proposal, known as Proposition 15 or the California Nuclear Initiative, that was the first of a series of state plebiscites challenging the continue expansion—or even further use—of nuclear power as an energy source. Similar referenda are now on the ballot in Oregon and Colorado for the November election and are being put forward in about 20 other states. The fights there promise to be no less vehement, and the partisans no less dedicated, than those surrouncing Proposition 15. As is often the case in American policy decisions, however, lawyers may have the last word: the nuclear initiative battle may ultimately turn on the legality of such proposals in light of the existing federal regulatory scheme set up by the Atomic Energy Act.