People ex rel. Deukmejian v. Brown, 29 Cal.3d 150, 624 P.2d 1206 (1981)

In People ex rel. Deukmejian v. Brown, 29 Cal.3d 150, 624 P.2d 1206 (1981), the California Supreme Court explicitly rejected the Feeney and Massachusetts approach and ruled that the California Attorney General has no common law authority and must subject to the Governor on litigation decisions.  It is also ruled that the California Attorney General is subject to the same attorney client duties as the private bar.  Although the actual practice in California remains murky, the Deukmejian decision stands and is the rule in a minority of other states.