 The reason is that the Legislature often failed to leave gaps in the section numbering in the California codes for future expansion, and then occasionally resorted to the shortsighted technique of appending an alphabetical letter to a section number in order to insert a new section between two existing sections on similar subject matter.For example, the summary judgment statute in California is Section 437c of the Code of Civil Procedure.But alphabetical letters are traditionally used in the U.S. to designate "subsections" of statutes.