one-subject rule (Oklahoma) · Go Syfert
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one-subject rule in Oklahoma

14 Oklahoma opinions name it 3 courts 1975–2011 0 in the last five years

The cases below were cited by Oklahoma 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 (7)

CaseFollowedCited
Campbell v. Whitegreen
okla · 1993 · cited in 6 Oklahoma opinions naming this issue, 1996–2011
2 sentences

2011T 27 In Campbell v. White, 1998 OK 89 , 856 P.2d 255, 258 , we rejected the broad, expansive theme approach to the single-subject requirement and said that legislation satisfies the one-subject requirement if the provisions are germane, relative and cognate to one another.

2009The proponents in Initiative Petition No. 382, like the respondents here, would have had us apply a broad expansive theme approach to the one-subject requirement. 23 120 However, in Imitiative Petition No. 382 we expressly rejected any broad, expansive, approach that may have been taken in prior cases and we do so again today. 24 In Font v. State ex rel Office of State Finance, 2008 OK 2 , 1 28, 184 P.8d 467 we said: Campbell v. White rejected the broad, expansive theme approach to the one-subject requirement. 1993 OK 89 , at T 8, 856 P.2d at 258 .

26
City of Oklahoma City v. Harrisgreen
okla · 1941 · cited in 1 Oklahoma opinions naming this issue, 1993–1993
2 sentences

1993Ruud, No Law Shall Embrace More Than One Subject, 42 Minn.L.Rev. 389, 448 (1958) (emphasis mine). [42] Village of Euclid v. Ambler Realty Co., 272 U.S. 365, 387 , 47 S.Ct. 114 , 118, 71 L.Ed. 303 (1927); Zahn v. Board of Public Works, 274 U.S. 325, 328 , 47 S.Ct. 594, 595 , 71 L.Ed. 1074 (1927); Beveridge v. Harper & Turner Oil Trust, 168 Okl. 609 , 35 P.2d 435, 439 (1934) (overruled in part on a different point of law in Oklahoma City v. Harris, 191 Okl. 125 , 126 P.2d 988, 989 (syllabus 2) (1942).

1993Ruud, No Law Shall Embrace More Than One Subject, 42 Minn.L.Rev. 389, 448 (1958) (emphasis mine). [42] Village of Euclid v. Ambler Realty Co., 272 U.S. 365, 387 , 47 S.Ct. 114 , 118, 71 L.Ed. 303 (1927); Zahn v. Board of Public Works, 274 U.S. 325, 328 , 47 S.Ct. 594, 595 , 71 L.Ed. 1074 (1927); Beveridge v. Harper & Turner Oil Trust, 168 Okl. 609 , 35 P.2d 435, 439 (1934) (overruled in part on a different point of law in Oklahoma City v. Harris, 191 Okl. 125 , 126 P.2d 988, 989 (syllabus 2) (1942).

11
Beveridge v. Harper & Turner Oil Trustgreen
okla · 1934 · cited in 1 Oklahoma opinions naming this issue, 1993–1993
2 sentences

1993Ruud, No Law Shall Embrace More Than One Subject, 42 Minn.L.Rev. 389, 448 (1958) (emphasis mine). [42] Village of Euclid v. Ambler Realty Co., 272 U.S. 365, 387 , 47 S.Ct. 114 , 118, 71 L.Ed. 303 (1927); Zahn v. Board of Public Works, 274 U.S. 325, 328 , 47 S.Ct. 594, 595 , 71 L.Ed. 1074 (1927); Beveridge v. Harper & Turner Oil Trust, 168 Okl. 609 , 35 P.2d 435, 439 (1934) (overruled in part on a different point of law in Oklahoma City v. Harris, 191 Okl. 125 , 126 P.2d 988, 989 (syllabus 2) (1942).

1993Ruud, No Law Shall Embrace More Than One Subject, 42 Minn.L.Rev. 389, 448 (1958) (emphasis mine). [42] Village of Euclid v. Ambler Realty Co., 272 U.S. 365, 387 , 47 S.Ct. 114 , 118, 71 L.Ed. 303 (1927); Zahn v. Board of Public Works, 274 U.S. 325, 328 , 47 S.Ct. 594, 595 , 71 L.Ed. 1074 (1927); Beveridge v. Harper & Turner Oil Trust, 168 Okl. 609 , 35 P.2d 435, 439 (1934) (overruled in part on a different point of law in Oklahoma City v. Harris, 191 Okl. 125 , 126 P.2d 988, 989 (syllabus 2) (1942).

11
Johnson v. Waltersgreen
okla · 1991 · cited in 1 Oklahoma opinions naming this issue, 1993–1993
2 sentences

1993Although the argument was not identified by the Legislature as a functional approach to consideration of the one-subject rule encompassed in art. 5, § 56, we were urged in Johnson v. Walters, 819 P.2d 694, 698 (Okla. 1991) to accept, as a single-subject, diverse legislation under a heading of "state government." We rejected this proposition because the adoption of an approach which would allow unrelated legislation to be included in a single enactment simply by the skillful drafting of a broad topic would defeat the purpose of the single-subject mandate of art. 5, § 56 — to prevent the executi

1993The necessity for strict compliance with the one-subject rule is thoroughly explained in Johnson v. Walters, 819 P.2d 694 (Okla. 1991).

11
In Re Initiative Petition No. 344, State Question No. 630green
okla · 1990 · cited in 1 Oklahoma opinions naming this issue, 1992–1992
1 sentence

1992See In re Initiative Petition No. 344, 797 P.2d 326 (Okla.1990); In re Initiative Petition No. 342, 797 P.2d 331 (Okla.1990); In re Initiative Petition No. 314, 625 P.2d 595 (Okla.1980) (all invalidated initiative petitions as violative of the one subject rule under State law).

11
Bond v. Phelpsgreen
okla · 1948 · cited in 1 Oklahoma opinions naming this issue, 1991–1991
2 sentences

1991"The purpose of the constitutional requirement that but a single subject be included in a legislative bill is to make impossible by log-rolling devices the enactment of unpopular legislation by including it with popular legislation on an entirely different subject." Bond v. Phelps, 200 Okla. 70, 82 , 191 P.2d 938, 950 (1948).

1991"The purpose of the constitutional requirement that but a single subject be included in a legislative bill is to make impossible by log-rolling devices the enactment of unpopular legislation by including it with popular legislation on an entirely different subject." Bond v. Phelps, 200 Okla. 70, 82 , 191 P.2d 938, 950 (1948).

11
Harbor v. Deukmejiangreen
cal · 1987 · cited in 1 Oklahoma opinions naming this issue, 1991–1991
2 sentences

1991See Harbor v. Deukmejian, 43 Cal.3d 1078 , 240 Cal. Rptr. 569, 578 , 742 P.2d 1290, 1299 (1987).

1991See Harbor v. Deukmejian, 43 Cal.3d 1078 , 240 Cal. Rptr. 569, 578 , 742 P.2d 1290, 1299 (1987).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (18)

CaseCitedYears
Black v. Oklahoma Funding Bond Commission green
okla · 1943
2 sentences

2009V, § 57 if the provisions are germane, relative, and cognate to one another, citing Black v. Oklahoma Funding Bd., 1948 OK [270, 198 Okla. 1 ], 140 P.2d 740, 748 .

2008V, § 57 if the provisions are germane, relative, and cognate to one another, citing Black v. Oklahoma Funding Bd., 1943 OK 270 , 193 Okla. 1 , 140 P.2d 740, 743 .

32008–2009
Public Service Co. of Oklahoma v. Fort Worth Grain Exchange green
okla · 1998
2 sentences

2011T 27 In Campbell v. White, 1998 OK 89 , 856 P.2d 255, 258 , we rejected the broad, expansive theme approach to the single-subject requirement and said that legislation satisfies the one-subject requirement if the provisions are germane, relative and cognate to one another.

2009V, § 56. 1998 OK 89 , at T 12, 856 P.2d at 260 .

22009–2011
Calvey v. Daxon green
· 2000
2 sentences

2008Without considering the desirability, wisdom, or practicality of the appropriations in H.B.1105, Calvey v. Daxon, 2000 OK 17, ¶ 21 , 997 P.2d 164, 171 , we observe that the Legislature should have adopted a separate special appropriation bill for each unrelated object or purpose of state government funded in H.B.1105 to satisfy the one-subject requirement, and it could have included language in each special appropriation bill that fixes the priority of the appropriation to the actual surplus funds.

2008Without considering the desirability, wisdom, or practicality of the appropriations in H.B.1105, Calvey v. Daxon, 2000 OK 17, ¶ 21 , 997 P.2d 164, 171 , we observe that the Legislature should have adopted a separate special appropriation bill for each unrelated object or purpose of state government funded in H.B.1105 to satisfy the one-subject requirement, and it could have included language in each special appropriation bill that fixes the priority of the appropriation to the actual surplus funds.

22008–2008
In Re Initiative Petition No. 314 green
okla · 1980
2 sentences

1992See In re Initiative Petition No. 344, 797 P.2d 326 (Okla.1990); In re Initiative Petition No. 342, 797 P.2d 331 (Okla.1990); In re Initiative Petition No. 314, 625 P.2d 595 (Okla.1980) (all invalidated initiative petitions as violative of the one subject rule under State law).

1992See In re Initiative Petition No. 344, 797 P.2d (Okla. 1990); In re Initiative Petition No. 342, 797 P.2d 331 (Okla. 1990); In re Initiative Petition No. 314, 625 P.2d 595 (Okla. 1980) (all invalidated initiative petition as violative of the one subject rule under State law).

21990–1992
Fent v. STATE EX REL. OFFICE OF STATE FIN. green
okla · 2008
1 sentence

2009The proponents in Initiative Petition No. 382, like the respondents here, would have had us apply a broad expansive theme approach to the one-subject requirement. 23 120 However, in Imitiative Petition No. 382 we expressly rejected any broad, expansive, approach that may have been taken in prior cases and we do so again today. 24 In Font v. State ex rel Office of State Finance, 2008 OK 2 , 1 28, 184 P.8d 467 we said: Campbell v. White rejected the broad, expansive theme approach to the one-subject requirement. 1993 OK 89 , at T 8, 856 P.2d at 258 .

12009–2009
Baulch v. Holcom neutral
okla · 1946
1 sentence

2009V, § 57 if the provisions are germane, relative, and cognate to one another, citing Black v. Oklahoma Funding Bd., 1948 OK [270, 198 Okla. 1 ], 140 P.2d 740, 748 .

12009–2009
In Re Initiative Petition No. 349, State Question No. 642 green
okla · 1992
1 sentence

1994In re Supreme Court Adjudication of Initiative Petitions in Norman, Oklahoma, 534 P.2d at 8 . [10] In In re Initiative Petition No. 349, State Question No. 642, 838 P.2d 1 (Okla. 1992), we considered a challenge to proposed legislation on abortion as facially violative of federal law. [11] In In re Initiative Petition No. 341, State Question No. 627, 796 P.2d 267 (Okla. 1990), we considered challenges to the face of a proposed constitutional amendment that would establish the Ethics Commission as facially violative of the First Amendment to the Constitution of the United States and the separat

11994–1994
Oklahomans for Modern Alcoholic Beverage Controls, Inc. v. Shelton green
okla · 1972
2 sentences

1994Const. Oklahomans for Modem Alcoholic Beverage Controls, Inc. v. Shelton, 501 P.2d 1089 (Okla. 1972), was handed-down in October, just before the 1973 amendments to § 8 of Title 34, wherein the need for this Court to consider facial violations of the one subject rule to prevent the chilling effect of multiple subjects on the right of the voters to express their opinions on a single subject was voiced.

1994Const. Oklahomans for Modern Alcoholic Beverage Controls, Inc. v. Shelton, 501 P.2d 1089 (Okla. 1972), was handed-down in October, just before the 1973 amendments to § 8 of Title 34, wherein the need for this Court to consider facial violations of the one subject rule to prevent the chilling effect of multiple subjects on the right of the voters to express their opinions on a single subject was voiced.

11994–1994
In Re Supreme Court Adjudication of Initiative Petitions in Norman green
okla · 1975
1 sentence

1994In re Supreme Court Adjudication of Initiative Petitions in Norman, Oklahoma, 534 P.2d at 8 . [10] In In re Initiative Petition No. 349, State Question No. 642, 838 P.2d 1 (Okla. 1992), we considered a challenge to proposed legislation on abortion as facially violative of federal law. [11] In In re Initiative Petition No. 341, State Question No. 627, 796 P.2d 267 (Okla. 1990), we considered challenges to the face of a proposed constitutional amendment that would establish the Ethics Commission as facially violative of the First Amendment to the Constitution of the United States and the separat

11994–1994
In Re Initiative Petition No. 341, State Question No. 627 green
okla · 1990
1 sentence

1994In re Supreme Court Adjudication of Initiative Petitions in Norman, Oklahoma, 534 P.2d at 8 . [10] In In re Initiative Petition No. 349, State Question No. 642, 838 P.2d 1 (Okla. 1992), we considered a challenge to proposed legislation on abortion as facially violative of federal law. [11] In In re Initiative Petition No. 341, State Question No. 627, 796 P.2d 267 (Okla. 1990), we considered challenges to the face of a proposed constitutional amendment that would establish the Ethics Commission as facially violative of the First Amendment to the Constitution of the United States and the separat

11994–1994
Zahn v. Board of Public Works green
scotus · 1927
2 sentences

1993Ruud, No Law Shall Embrace More Than One Subject, 42 Minn.L.Rev. 389, 448 (1958) (emphasis mine). [42] Village of Euclid v. Ambler Realty Co., 272 U.S. 365, 387 , 47 S.Ct. 114 , 118, 71 L.Ed. 303 (1927); Zahn v. Board of Public Works, 274 U.S. 325, 328 , 47 S.Ct. 594, 595 , 71 L.Ed. 1074 (1927); Beveridge v. Harper & Turner Oil Trust, 168 Okl. 609 , 35 P.2d 435, 439 (1934) (overruled in part on a different point of law in Oklahoma City v. Harris, 191 Okl. 125 , 126 P.2d 988, 989 (syllabus 2) (1942).

1993Ruud, No Law Shall Embrace More Than One Subject, 42 Minn.L.Rev. 389, 448 (1958) (emphasis mine). [42] Village of Euclid v. Ambler Realty Co., 272 U.S. 365, 387 , 47 S.Ct. 114 , 118, 71 L.Ed. 303 (1927); Zahn v. Board of Public Works, 274 U.S. 325, 328 , 47 S.Ct. 594, 595 , 71 L.Ed. 1074 (1927); Beveridge v. Harper & Turner Oil Trust, 168 Okl. 609 , 35 P.2d 435, 439 (1934) (overruled in part on a different point of law in Oklahoma City v. Harris, 191 Okl. 125 , 126 P.2d 988, 989 (syllabus 2) (1942).

11993–1993
Village of Euclid v. Ambler Realty Co. green
scotus · 1926
2 sentences

1993Ruud, No Law Shall Embrace More Than One Subject, 42 Minn.L.Rev. 389, 448 (1958) (emphasis mine). [42] Village of Euclid v. Ambler Realty Co., 272 U.S. 365, 387 , 47 S.Ct. 114 , 118, 71 L.Ed. 303 (1927); Zahn v. Board of Public Works, 274 U.S. 325, 328 , 47 S.Ct. 594, 595 , 71 L.Ed. 1074 (1927); Beveridge v. Harper & Turner Oil Trust, 168 Okl. 609 , 35 P.2d 435, 439 (1934) (overruled in part on a different point of law in Oklahoma City v. Harris, 191 Okl. 125 , 126 P.2d 988, 989 (syllabus 2) (1942).

1993Ruud, No Law Shall Embrace More Than One Subject, 42 Minn.L.Rev. 389, 448 (1958) (emphasis mine). [42] Village of Euclid v. Ambler Realty Co., 272 U.S. 365, 387 , 47 S.Ct. 114 , 118, 71 L.Ed. 303 (1927); Zahn v. Board of Public Works, 274 U.S. 325, 328 , 47 S.Ct. 594, 595 , 71 L.Ed. 1074 (1927); Beveridge v. Harper & Turner Oil Trust, 168 Okl. 609 , 35 P.2d 435, 439 (1934) (overruled in part on a different point of law in Oklahoma City v. Harris, 191 Okl. 125 , 126 P.2d 988, 989 (syllabus 2) (1942).

11993–1993
In Re Initiative Petition No. 342, State Question No. 628 green
okla · 1990
2 sentences

1992See In re Initiative Petition No. 344, 797 P.2d 326 (Okla.1990); In re Initiative Petition No. 342, 797 P.2d 331 (Okla.1990); In re Initiative Petition No. 314, 625 P.2d 595 (Okla.1980) (all invalidated initiative petitions as violative of the one subject rule under State law).

1992See In re Initiative Petition No. 344, 797 P.2d (Okla. 1990); In re Initiative Petition No. 342, 797 P.2d 331 (Okla. 1990); In re Initiative Petition No. 314, 625 P.2d 595 (Okla. 1980) (all invalidated initiative petition as violative of the one subject rule under State law).

11992–1992
State Ex Rel. Wiseman v. Oklahoma Board of Corrections green
okla · 1980
2 sentences

1991The decision notes that following the application of sections 11 and 12, no issue of one-subject compliance remained because only the appropriation provisions were enacted into law. 614 P.2d at 557 .

1991The decision notes that following the application of sections 11 and 12, no issue of one-subject compliance remained because only the appropriation provisions were enacted into law. 614 P.2d at 557 .

11991–1991
Kerby v. Luhrs green
ariz · 1934
1 sentence

1990Id.

11990–1990
National Mutual Casualty Co. v. Briscoe green
okla · 1940
2 sentences

1980Casualty Co. v. Briscoe, 188 Okl. 440 , 109 P.2d 1088 (1940), this Court in dealing with the one-subject requirement of §§ 56 and 57 quoted from Griffin v. Thomas, 86 Okl. 70 , 206 P. 604 (1922) and said: The term ‘subject’, as used in these provisions, is to be given a broad and extended meaning, so as to allow the Legislature full scope to include in one act all matters having a logical or natural connection.

1980Casualty Co. v. Briscoe, 188 Okl. 440 , 109 P.2d 1088 (1940), this Court in dealing with the one-subject requirement of §§ 56 and 57 quoted from Griffin v. Thomas, 86 Okl. 70 , 206 P. 604 (1922) and said: The term ‘subject’, as used in these provisions, is to be given a broad and extended meaning, so as to allow the Legislature full scope to include in one act all matters having a logical or natural connection.

11980–1980
Griffin v. Thomas green
okla · 1922
2 sentences

1980Casualty Co. v. Briscoe, 188 Okl. 440 , 109 P.2d 1088 (1940), this Court in dealing with the one-subject requirement of §§ 56 and 57 quoted from Griffin v. Thomas, 86 Okl. 70 , 206 P. 604 (1922) and said: The term ‘subject’, as used in these provisions, is to be given a broad and extended meaning, so as to allow the Legislature full scope to include in one act all matters having a logical or natural connection.

1980Casualty Co. v. Briscoe, 188 Okl. 440 , 109 P.2d 1088 (1940), this Court in dealing with the one-subject requirement of §§ 56 and 57 quoted from Griffin v. Thomas, 86 Okl. 70 , 206 P. 604 (1922) and said: The term ‘subject’, as used in these provisions, is to be given a broad and extended meaning, so as to allow the Legislature full scope to include in one act all matters having a logical or natural connection.

11980–1980
Rupe v. Shaw green
okla · 1955
1 sentence

1975Rupe v. Shaw, supra. It is, therefore, the opinion of the Attorney General that your question be answered in the negative.

11975–1975

Where else courts name it

OH 81 (1984–2022) 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) IN 5 (1981–2024) AL 4 (1982–1992) NE 4 (1996–2024) AZ 4 (1926–1990) IL 4 (1974–1998) TN 4 (1937–1974) SC 3 (2008–2021) NV 2 (2006–2008) NY 2 (1941–2017) WV 2 (1993–1993)

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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