The Sacramento Bee quoted Professor John Eastman in an article entitled, “A Roadblock to Pension Reform? Constitutional Clause Could Limit Changes.” In the article, Professor Eastman agreed with Governor Jerry Brown’s constitutional interpretation regarding modifying public pension plans. Professor Eastman told the Bee that public pension plans can be modified if there is “a real serious fiscal problem, a dire financial need-and the system is underfunded.” Professor Eastman added, “Given the circumstances in California, I think we would meet the legal requirement.”