Various legal scholars have questioned the constitutionality of the California gubernatorial recall rules. See this Politico story. The second half of the story suggests that California should not have allowed any candidates to file to become the new Governor, because the state constitution says that when there is a vacancy in the office of Governor, the Lieutenant Governor becomes Governor. But, the precedent against that idea was set in the 2003 gubernatorial recall.
The problem in the first half of this article is caused by section 11381(c), which says, “No person whose recall is being sought may be a candidate to succeed himself or herself.” On the other hand, voters are still free to cast a write-in vote for Gavin Newsom, because section 11322 says write-in space should be on the ballot. The Newsom votes won’t be counted, but if there were a lawsuit involving the first problem mentioned in the Politico story, a court could order them to be counted.