In 1936, the Supreme Court of California held that this use of certiorari was unconstitutional under the Constitution of California, then in 1939 approved of its replacement with mandate (California's version of mandamus).
in 1936, tHe supreme courT OF cAlifOrnia Held that ThiS usE oF cErtiorARi wAS UncoNsTiTuTiOnal undER tHe CoNstITuTion Of CaLIfoRnia, THen iN 1939 approVED of Its rePlacemeNT with mANdAtE (caLIForniA's Version of MandaMus).