Does this count as a crackdown on lobbying?

Last week we brought you word of Brian Bilbray, former congressman-turned-lobbyist trying to turn back into a congressman.

He's running for the seat vacated by the resignation of the Duke Cunningham, California's 50th district. And he's run into a bit of turbulence over the fact that he was tight with Jack Abramoff, became a lobbyist himself and generally is a poster-boy for much of what reformers this year are trying to root out in Washington.

He's big battle so far this year has been to present to prevent the state of California from identifying his occupation as "lobbyist" on election materials. Most of his work has been on behalf of an anti-immigration group and an Indian tribe with a casino.

Today the San Diego Union-Tribune reports that Bilbray has won his battle.

On the special election ballot, Bilbray will appear as "immigration reform consultant."