The powers of an acting governor came into dispute during the 1980 Democratic primary presidential campaign of Jerry Brown, then governor of California. When he was campaigning out of state, which was often in late 1979 and early 1980, Mike Curb, a Republican who was then serving as lieutenant governor of California often used his position as acting governor to veto legislation, promulgate executive orders, issue proclamations, appoint Republican appellate court justices, and to do other things that Brown would not likely have done had he been present in the state. This eventually resulted in litigation, much of which went in Curb's favor.
