one-subject requirement (Florida) · Go Syfert
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one-subject requirement in Florida

19 Florida opinions name it 2 courts 1981–2019 0 in the last five years

The cases below were cited by Florida courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (9)

CaseFollowedCited
Rianhard v. Port of Palm Beach Districtgreen
fla · 1966 · cited in 2 Florida opinions naming this issue, 1981–1981
2 sentences

1981We held that article VII, section 10 of our Constitution did not prevent this type of financing because such facilities serve a paramount public purpose and provide only incidental benefits to a private corporation. *1225 Nor do we accept appellants' contention that the 1980 amendment embraces more than one subject. [4] This Court has held that the one-subject requirement is not violated so long as all of the provisions appear to be "incidentally related and properly connected to primary subjects expressed in the title and naturally germane thereto." Rianhard v. Port of Palm Beach District, 18

1981Nor do we accept appellants’ contention that the 1980 amendment embraces more than one subject. 4 This Court has held that the one-subject requirement is not violated so long as all of the provisions appear to be “incidentally related and properly connected to primary subjects expressed in the title and naturally germane thereto.” Rianhard v. Port of Palm Beach District, 186 So.2d 503, 506 (Fla.1966).

22
State v. Leegreen
fla · 1978 · cited in 4 Florida opinions naming this issue, 1981–1990
2 sentences

1990Although in Smith we said that the one-subject requirement must be applied with common sense, and in Chenoweth v. Kemp, 396 So.2d 1122 (Fla. 1981), and State v. Lee, 356 So.2d 276 (Fla. 1978), we noted that the legislature has wide latitude in the enactment of acts, provided that matters included in acts have a natural and logical connection, these propositions do not militate against the requirement that the matters included in an act must bear a logical and natural connection, and must be germane to one another.

1981“The subject of a law is that which is expressed in the title .. . and it may be as broad as the legislature chooses provided the matters included in the law have a natural and logical connection.” State v. Lee, 356 So.2d 276 (Fla.1978).

14
State v. Burchgreen
fladistctapp · 1989 · cited in 4 Florida opinions naming this issue, 1989–1989
2 sentences

1989Blankenship, et al. v. State, 545 So.2d 908 (2d DCA 1989); State v. Burch, 545 So.2d 279 (4th DCA, 1989).

1989State v. Burch, 545 So.2d 279 (Fla. 4th DCA 1989); Blankenship v. State, 545 So.2d 908 (Fla. 2d DCA 1989).

14
Brown v. Firestonegreen
fla · 1980 · cited in 2 Florida opinions naming this issue, 1999–2019
2 sentences

2019Id.

1999See Brown v. Firestone, 382 So.2d 654, 663 (Fla.1980).

12
Division of Bond Finance v. Smathersgreen
fla · 1976 · cited in 1 Florida opinions naming this issue, 1999–1999
1 sentence

1999Mandamus is the appropriate vehicle for addressing the constitutionality of the provisos only “where the functions of government will be adversely affected without an immediate determination.” Division of Bond Finance v. Smathers, 337 So.2d 805, 807 (Fla.1976); see also Dickinson v. Stone, 251 So.2d 268, 271 (Fla.1971).

11
Fine v. Firestonegreen
fla · 1984 · cited in 1 Florida opinions naming this issue, 1999–1999
1 sentence

1999See 448 So.2d at 988-89 .

11
Dickinson v. Stonegreen
fla · 1971 · cited in 1 Florida opinions naming this issue, 1999–1999
1 sentence

1999Mandamus is the appropriate vehicle for addressing the constitutionality of the provisos only “where the functions of government will be adversely affected without an immediate determination.” Division of Bond Finance v. Smathers, 337 So.2d 805, 807 (Fla.1976); see also Dickinson v. Stone, 251 So.2d 268, 271 (Fla.1971).

11
Bennett v. Stategreen
fladistctapp · 1989 · cited in 1 Florida opinions naming this issue, 1990–1990
1 sentence

1990In Bennett v. State, 546 So.2d 1192, 1192 (Fla.2d DCA 1989), the district court certified the following question as being of great public interest: “Does section 893.-13(l)(e), Florida Statutes (1987), violate the one subject rule of article III, section 6 of the Florida Constitution?” We answered this question in the negative and held the statute to be constitutional in Burch v. State, 558 So.2d 1 (Fla.1990), and, therefore, approve Bennett .

11
Weber v. Smathersgreen
fla · 1976 · cited in 1 Florida opinions naming this issue, 1984–1984
1 sentence

1984As Justice England recognized and as Justice Roberts prophesied, this Court's discussion and holding on the second point in Floridians has made the constitution "subject to potentially devasting effects from ... initiative petitions having subjects framed as broadly as the mind can devise." Weber, 338 So.2d at 823 (England, J., concurring).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Florida. Read the followed side critically anyway.

Also cited on this issue (11)

CaseCitedYears
Blankenship v. State green
fladistctapp · 1989
2 sentences

1989Were it not for the precedent this court has already established in Blankenship, et al. v. State, 545 So.2d 908 (Fla. 2d DCA 1989) (Hall, J., Dissenting) and Lewis v. State, 545 So.2d 427 (Fla. 2d DCA 1989), I would agree with Judge Hall's dissent in *1193 Blankenship and hold that chapter 87-243, Laws of Florida, violates the one subject requirement of article III, section 6 of the Florida Constitution.

1989We recently rejected this argument in Blankenship v. State, 545 So.2d 908 (Fla. 2d DCA 1989) (Hall, J., Dissenting), and held that chapter 87-243 did not violate the one subject rule.

31989–1989
Heggs v. State green
fla · 2000
2 sentences

2004"The one-subject rule declares that this perversion of majority rule will not be tolerated." Heggs, 759 So.2d at 630 (quoting Ruud, 42 Minn. L.Rev. at 399).

2004It is aimed at log-rolling." 759 So.2d at 630 (quoting Millard H.

22003–2004
McCall v. State green
fladistctapp · 1991
2 sentences

1992As to the issue of whether section 775.084, Florida Statutes (1989), amendments to the habitual offender statute, violated the one subject rule of the *375 Florida Constitution, we affirm on the authority of this court's opinions in Jamison v. State, 583 So.2d 413 (Fla. 4th DCA), review denied, 591 So.2d 182 (Fla. 1991), and McCall v. State, 583 So.2d 411 (Fla. 4th DCA 1991), review granted, 593 So.2d 1052 (Fla. 1992).

1992Jamison v. State, 583 So.2d 413 (Fla. 4th DCA 1991); rev. denied, 591 So.2d 182 (Fla. 1991); McCall v. State, 583 So.2d 411 (Fla. 4th DCA 1991) rev. granted, 17 F.L.W.

21992–1992
Jamison v. State green
fladistctapp · 1991
2 sentences

1992As to the issue of whether section 775.084, Florida Statutes (1989), amendments to the habitual offender statute, violated the one subject rule of the *375 Florida Constitution, we affirm on the authority of this court's opinions in Jamison v. State, 583 So.2d 413 (Fla. 4th DCA), review denied, 591 So.2d 182 (Fla. 1991), and McCall v. State, 583 So.2d 411 (Fla. 4th DCA 1991), review granted, 593 So.2d 1052 (Fla. 1992).

1992Jamison v. State, 583 So.2d 413 (Fla. 4th DCA 1991); rev. denied, 591 So.2d 182 (Fla. 1991); McCall v. State, 583 So.2d 411 (Fla. 4th DCA 1991) rev. granted, 17 F.L.W.

21992–1992
Burch v. State green
fla · 1990
2 sentences

1990V, § 3(b)(3), Fla. Const. We approve the decision based on our holding in Burch v. State, 558 So.2d 1 (Fla.1990), wherein we ruled that chapter 87-243, Laws of Florida, did not violate the one-subject rule.

1990In Bennett v. State, 546 So.2d 1192, 1192 (Fla.2d DCA 1989), the district court certified the following question as being of great public interest: “Does section 893.-13(l)(e), Florida Statutes (1987), violate the one subject rule of article III, section 6 of the Florida Constitution?” We answered this question in the negative and held the statute to be constitutional in Burch v. State, 558 So.2d 1 (Fla.1990), and, therefore, approve Bennett .

21990–1990
State v. Combs green
fla · 1980
1 sentence

1992Johnson , is predicated on two factors: (1) appellant Johnson had standing to challenge the constitutionality of Chapter 89-280 because his offense was committed within the time period between the October 1, 1989, effective date of the 1989 amendments to the habitual felony offender provisions and their re-enactment, effective May 2, 1991, as a part of the Florida Statutes, See State v. Combs, 388 So.2d 1029 (Fla. 1980); (2) appellant Johnson could only be classified an habitual violent felony offender under the amended statute, as the offense which served as a basis for his classification as

11992–1992
Johnson v. State green
fladistctapp · 1991
1 sentence

1992However, the First District in Johnson v. State, 589 So.2d 1370 (Fla. 1st DCA 1991), held that section 775.084, as amended by Chapter 89-280, Laws of Florida, violated the one subject rule from October 1, 1989, the effective date of the amendments, to May 2, 1991, the date of their re-enactment. [1] Therefore, we certify that this opinion is in direct conflict with Johnson and also certify the following question, which we adopt from Johnson , to be of great public importance: WHETHER THE CHAPTER 89-280 AMENDMENTS TO SECTION 775.084(1)(A)1, FLORIDA STATUTES (1989), WERE UNCONSTITUTIONAL PRIOR T

11992–1992
Chenoweth v. Kemp red
fla · 1981
1 sentence

1990Although in Smith we said that the one-subject requirement must be applied with common sense, and in Chenoweth v. Kemp, 396 So.2d 1122 (Fla. 1981), and State v. Lee, 356 So.2d 276 (Fla. 1978), we noted that the legislature has wide latitude in the enactment of acts, provided that matters included in acts have a natural and logical connection, these propositions do not militate against the requirement that the matters included in an act must bear a logical and natural connection, and must be germane to one another.

11990–1990
Lewis v. State green
fladistctapp · 1989
1 sentence

1989Were it not for the precedent this court has already established in Blankenship, et al. v. State, 545 So.2d 908 (Fla. 2d DCA 1989) (Hall, J., Dissenting) and Lewis v. State, 545 So.2d 427 (Fla. 2d DCA 1989), I would agree with Judge Hall's dissent in *1193 Blankenship and hold that chapter 87-243, Laws of Florida, violates the one subject requirement of article III, section 6 of the Florida Constitution.

11989–1989
Adams v. Gunter green
fla · 1970
1 sentence

1984Prior to its amendment in 1972, article XI, section 3 provided in part: "The power to propose amendments to any section of this constitution by initiative is reserved to the people." In Adams v. Gunter, 238 So.2d 824 (Fla. 1970), the Court analyzed the various ways of amending the constitution as provided in article XI and also analyzed the effect on the constitution of the proposed amendment creating a unicameral legislature.

11984–1984
Colonial Investment Co. v. Nolan green
fla · 1930
1 sentence

1981Id.

11981–1981

Statutes the citing opinions construe

FL § 893.13 (6) FL § 775.084 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

OH 85 (1984–2026) FL 19 (1981–2019) OK 14 (1975–2011) OR 8 (1984–2002) CA 8 (1979–2016) AK 7 (1979–2020) IA 7 (1966–2022) TX 6 (1990–2015) MD 5 (1990–2022) AL 5 (1975–1992) IN 5 (1981–2024) NE 4 (1996–2024) TN 4 (1937–1974) SC 4 (1947–2021) IL 4 (1974–1998) AZ 4 (1926–1990) ND 3 (1981–2023) NY 2 (1941–2017) WV 2 (1993–1993) NV 2 (2006–2008)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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