A California corporation begins existence upon the filing of its articles of incorporation. Cal. Corp. Code § 200(c). The filing of initial articles of incorporation starts a 90 day clock on the filing of the newly hatched corporation's initial statement of information. Cal. Corp. Code § 1502(a). It therefore would seem to be most efficient to submit the articles and the statement of information for filing at the same time. This, however, is not possible.

The reason is that the statement of information must include the Secretary of State's file number, Cal. Corp. Code § 1502(a)(1), and a file number is not assigned until the articles of incorporation have been filed. Thus, the Secretary of State's office will not accept "1 of 2, 2 of 2" filing submissions of this type.

Is A World Without Chevron Even Imaginable?

As has been widely noted, the United States Supreme Court heard oral arguments yesterday in Loper Bright Enterprises v. Raimondo. Although commentators have handicapped the case differently, it is possible that the Supreme Court will overturn the deferential standard of judicial review of agency interpretations adopted in Chevron, U.S.A., Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837 (1984). Some have predicted that if the Supreme Court disavows Chevron deference, chaos will ensue. Some readers, however, may recall my 2016 post that California courts do not follow Chevron when reviewing state agency interpretations. Thus, it is not only possible to imagine a "world without Chevron", but it is even possible to live in one!