single-subject rule in Iowa

2022Finally, it keeps the citizens of the state fairly informed of the subjects the legislature is considering. 460 N.W.2d at 473 (citations omitted).9 The single-subject requirement is primarily aimed at the first of these purposes: avoiding logrolling.

2022We note, however, that Mabry referred to the single-subject requirement and the title requirement together as the “single-subject rule.” See id. (“Most state constitutions require that ‘no [legislative] act shall contain more than one subject, which shall be expressed in its title. . . .’ This constitutional mandate is known as the ‘single-subject’ rule.” (omission in original) (quoting 1A Norman J.

2022Miller v. Bair, 444 N.W.2d 487, 489 (Iowa 1989) (“[I]n order for a violation of the single-subject requirement to exist, the challenged legislation must embrace ‘two or more dissimilar and discordant subjects that by no fair intendment can be considered as having any legitimate connection with or relation to each other.’ ” (quoting Long v. Bd. of Supervisors, 142 N.W.2d 378, 381 (Iowa 1966))); Christie v. Life Indem. & Inv.

2022Ct., 410 N.W.2d at 685, 687 (determining that a provision removing magistrates’ jurisdiction over first offense operating while intoxicated did not violate the single-subject rule even though the rest of the bill addressed the transportation of alcohol, the Sunday sale of alcohol, and the topic of minors and alcohol because all provisions were “rationally related to the 25 regulation of alcohol and its consumption or possession”); Webster Realty Co. v. City of Fort Dodge, 174 N.W.2d 413, 418 (Iowa 1970) (finding that “planning, achieving, and financing urban renewal” was one subject); Frost v.

2023Ct., 410 N.W.2d at 686 ). 31 The single-subject requirement primarily prevents logrolling.

2022Ct., 410 N.W.2d at 685, 687 (determining that a provision removing magistrates’ jurisdiction over first offense operating while intoxicated did not violate the single-subject rule even though the rest of the bill addressed the transportation of alcohol, the Sunday sale of alcohol, and the topic of minors and alcohol because all provisions were “rationally related to the 25 regulation of alcohol and its consumption or possession”); Webster Realty Co. v. City of Fort Dodge, 174 N.W.2d 413, 418 (Iowa 1970) (finding that “planning, achieving, and financing urban renewal” was one subject); Frost v.

2022We tracked our earlier decision in Western International and again held that substantive legislation within a code-corrections bill violates the single-subject rule: “When [a code-correction] bill incorporates substantive changes, however, the portions that violate article III, section 29 must be stricken.” Id.

2022We tracked our earlier decision in Western International and again held that substantive legislation within a code-corrections bill violates the single-subject rule: “When [a code-correction] bill incorporates substantive changes, however, the portions that violate article III, section 29 must be stricken.” Id.

2022Miller v. Bair, 444 N.W.2d 487, 489 (Iowa 1989) (“[I]n order for a violation of the single-subject requirement to exist, the challenged legislation must embrace ‘two or more dissimilar and discordant subjects that by no fair intendment can be considered as having any legitimate connection with or relation to each other.’ ” (quoting Long v. Bd. of Supervisors, 142 N.W.2d 378, 381 (Iowa 1966))); Christie v. Life Indem. & Inv.

2022Miller v. Bair, 444 N.W.2d 487, 489 (Iowa 1989) (“[I]n order for a violation of the single-subject requirement to exist, the challenged legislation must embrace ‘two or more dissimilar and discordant subjects that by no fair intendment can be considered as having any legitimate connection with or relation to each other.’ ” (quoting Long v. Bd. of Supervisors, 142 N.W.2d 378, 381 (Iowa 1966))); Christie v. Life Indem. & Inv.

2022State v. Taylor, 557 N.W.2d 523 (Iowa 1996), marked the third and only other time this court has found a violation of the single-subject rule.

2022State v. Taylor, 557 N.W.2d 523 (Iowa 1996), marked the third and only other time this court has found a violation of the single-subject rule.

2022Hygiene, Inc., 156 N.W.2d 288, 289, 292 (Iowa 1968) (finding that a bill with the stated purpose of “suppress[ing] the vending of articles of indecent and immoral use” that had a section criminalizing the sale of contraceptives in vending machines did not violate the single-subject rule because “the listing by the legislature of what it considers indecent and immoral is within the limitations of the Constitution”); Rains v. First Nat’l Bank of Fairfield, 206 N.W. 821, 822 (Iowa 1926) (holding that provisions governing appellate procedure in the supreme court and other provisions setting qualif

2022Hygiene, Inc., 156 N.W.2d 288, 289, 292 (Iowa 1968) (finding that a bill with the stated purpose of “suppress[ing] the vending of articles of indecent and immoral use” that had a section criminalizing the sale of contraceptives in vending machines did not violate the single-subject rule because “the listing by the legislature of what it considers indecent and immoral is within the limitations of the Constitution”); Rains v. First Nat’l Bank of Fairfield, 206 N.W. 821, 822 (Iowa 1926) (holding that provisions governing appellate procedure in the supreme court and other provisions setting qualif

2022We merely note that the delegates ultimately chose what they intended to be the broader word. 23 of Villisca, 261 N.W. 423, 425 (Iowa 1935) (describing the “obvious . . . intention on the part of the framers . . . to give [the single-subject rule] a liberal construction” and collecting early cases that support that conclusion).

2022We merely note that the delegates ultimately chose what they intended to be the broader word. 23 of Villisca, 261 N.W. 423, 425 (Iowa 1935) (describing the “obvious . . . intention on the part of the framers . . . to give [the single-subject rule] a liberal construction” and collecting early cases that support that conclusion).

2022Ct., 410 N.W.2d at 685, 687 (determining that a provision removing magistrates’ jurisdiction over first offense operating while intoxicated did not violate the single-subject rule even though the rest of the bill addressed the transportation of alcohol, the Sunday sale of alcohol, and the topic of minors and alcohol because all provisions were “rationally related to the 25 regulation of alcohol and its consumption or possession”); Webster Realty Co. v. City of Fort Dodge, 174 N.W.2d 413, 418 (Iowa 1970) (finding that “planning, achieving, and financing urban renewal” was one subject); Frost v.

2022Ct., 410 N.W.2d at 685, 687 (determining that a provision removing magistrates’ jurisdiction over first offense operating while intoxicated did not violate the single-subject rule even though the rest of the bill addressed the transportation of alcohol, the Sunday sale of alcohol, and the topic of minors and alcohol because all provisions were “rationally related to the 25 regulation of alcohol and its consumption or possession”); Webster Realty Co. v. City of Fort Dodge, 174 N.W.2d 413, 418 (Iowa 1970) (finding that “planning, achieving, and financing urban renewal” was one subject); Frost v.

2022Ct., 410 N.W.2d at 685, 687 (determining that a provision removing magistrates’ jurisdiction over first offense operating while intoxicated did not violate the single-subject rule even though the rest of the bill addressed the transportation of alcohol, the Sunday sale of alcohol, and the topic of minors and alcohol because all provisions were “rationally related to the 25 regulation of alcohol and its consumption or possession”); Webster Realty Co. v. City of Fort Dodge, 174 N.W.2d 413, 418 (Iowa 1970) (finding that “planning, achieving, and financing urban renewal” was one subject); Frost v.

2022Ct., 410 N.W.2d at 685, 687 (determining that a provision removing magistrates’ jurisdiction over first offense operating while intoxicated did not violate the single-subject rule even though the rest of the bill addressed the transportation of alcohol, the Sunday sale of alcohol, and the topic of minors and alcohol because all provisions were “rationally related to the 25 regulation of alcohol and its consumption or possession”); Webster Realty Co. v. City of Fort Dodge, 174 N.W.2d 413, 418 (Iowa 1970) (finding that “planning, achieving, and financing urban renewal” was one subject); Frost v.

2022Hygiene, Inc., 156 N.W.2d 288, 289, 292 (Iowa 1968) (finding that a bill with the stated purpose of “suppress[ing] the vending of articles of indecent and immoral use” that had a section criminalizing the sale of contraceptives in vending machines did not violate the single-subject rule because “the listing by the legislature of what it considers indecent and immoral is within the limitations of the Constitution”); Rains v. First Nat’l Bank of Fairfield, 206 N.W. 821, 822 (Iowa 1926) (holding that provisions governing appellate procedure in the supreme court and other provisions setting qualif

2022Hygiene, Inc., 156 N.W.2d 288, 289, 292 (Iowa 1968) (finding that a bill with the stated purpose of “suppress[ing] the vending of articles of indecent and immoral use” that had a section criminalizing the sale of contraceptives in vending machines did not violate the single-subject rule because “the listing by the legislature of what it considers indecent and immoral is within the limitations of the Constitution”); Rains v. First Nat’l Bank of Fairfield, 206 N.W. 821, 822 (Iowa 1926) (holding that provisions governing appellate procedure in the supreme court and other provisions setting qualif

2022Co., 48 N.W. 94, 96 (Iowa 1891) (“It is not true that an act may not embrace more than one subject.

2022Co., 48 N.W. 94, 96 (Iowa 1891) (“It is not true that an act may not embrace more than one subject.

2008Id. at 410-11 , 111 S.Ct. at 1370-71 , 113 L.Ed.2d at 425 (providing that to establish third-party standing, litigant must have suffered an “injury in fact” so as to give the litigant a sufficient concrete interest in the outcome of the dispute); ICLU v. Critelli, 244 N.W.2d 564, 567 (Iowa 1976) (holding Iowa Civil Liberties Union and lawyers lacked standing to maintain action to challenge a supervisory order of the court pertaining to the trial of criminal cases — only defendants in the criminal cases had standing).

2008Id. at 410-11 , 111 S.Ct. at 1370-71 , 113 L.Ed.2d at 425 (providing that to establish third-party standing, litigant must have suffered an “injury in fact” so as to give the litigant a sufficient concrete interest in the outcome of the dispute); ICLU v. Critelli, 244 N.W.2d 564, 567 (Iowa 1976) (holding Iowa Civil Liberties Union and lawyers lacked standing to maintain action to challenge a supervisory order of the court pertaining to the trial of criminal cases — only defendants in the criminal cases had standing).

2022Additionally, Godfrey and Rush involved more limited challenges—Godfrey, 752 N.W.2d at 427 , had only a single-subject challenge and Rush, 2020 WL 825953 , at *8, made both a single- subject and a title challenge.

2020Godfrey and plaintiffs’ claims In Godfrey, the plaintiff challenged legislation as violating the single-subject rule of article III, section 29 of the Iowa Constitution. 752 N.W.2d at 416 .

1997In Western International v. Kirkpatrick, 396 N.W.2d 359 (Iowa 1986), we set forth the principles and underlying cases that are instructive in applying this constitutional provision.

1997In Western International v. Kirkpatrick, 396 N.W.2d 359 (Iowa 1986), we set forth the principles and underlying cases that are instructive in applying this constitutional provision.

2008Id. at 410-11 , 111 S.Ct. at 1370-71 , 113 L.Ed.2d at 425 (providing that to establish third-party standing, litigant must have suffered an "injury in fact" so as to give the litigant a sufficient concrete interest in the outcome of the dispute); ICLU v. Critelli, 244 N.W.2d 564, 567 (Iowa 1976) (holding Iowa Civil Liberties Union and lawyers lacked standing to maintain action to challenge a supervisory order of the court pertaining to the trial of criminal cases—only defendants in the criminal cases had standing).

2008Id. at 410-11 , 111 S.Ct. at 1370-71 , 113 L.Ed.2d at 425 (providing that to establish third-party standing, litigant must have suffered an “injury in fact” so as to give the litigant a sufficient concrete interest in the outcome of the dispute); ICLU v. Critelli, 244 N.W.2d 564, 567 (Iowa 1976) (holding Iowa Civil Liberties Union and lawyers lacked standing to maintain action to challenge a supervisory order of the court pertaining to the trial of criminal cases — only defendants in the criminal cases had standing).