one-subject rule in Ohio

2022Relations Bd., 104 Ohio St.3d 122 , 2004- Ohio-6363, 818 N.E.2d 688 , ¶ 28. 1) R.C. 1901.20(A)(1) and R.C. 1907.02(C) {¶ 29} Initially, we must determine whether there was a violation of the one-subject rule within the context of an appropriations bill.

2021Relations Bd., 104 Ohio St.3d 122 , 2004- Ohio-6363, 818 N.E.2d 688 , ¶ 28. {¶ 52} In this case, we must determine whether there was a violation of the one- subject rule within the context of an appropriations bill.

2014Ohio AFL-CIO v. Voinovich, 69 Ohio St.3d 225, 230 , 631 N.E.2d 582 (1994) (severing the portion of a bill that violated the one-subject rule); State ex rel.

2014Ohio AFL-CIO v. Voinovich, 69 Ohio St.3d 225, 230 , 631 N.E.2d 582 (1994) (severing the portion of a bill that violated the one-subject rule); State ex rel.

2022Dayton I, 2021-Ohio-967 , 170 N.E.3d 502, at ¶ 52 . “[T]he analysis of the one-subject rule with respect to appropriation bills can be complicated because appropriations bills ‘encompass many items, all bound by the thread of appropriations.’ ” Rumpke Sanitary Landfill, Inc. v. Ohio, 184 Ohio App.3d 135 , 2009-Ohio-4888 , 919 N.E.2d 826 , ¶ 16 (1st Dist.), quoting Simmons-Harris v. Goff, 86 Ohio St.3d 1, 16 , 711 N.E.2d 203 (1999). {¶ 30} In our view, the exclusive-jurisdiction provisions in R.C. 1901.20(A)(1) and R.C. 1907.02(C) “directly relate to the authorization and conditions of the oper

2021In this case, we must determine whether there is an alleged violation of the one-subject rule within the context of an appropriations bill. “[T]he analysis of the one-subject rule with respect to appropriation bills can be complicated because appropriations bills ‘encompass many items, all bound by the thread of appropriations.’” Rumpke Sanitary Landfill, Inc. v. Ohio, 184 Ohio App.3d 135 , 2009-Ohio-4888 , 919 N.E.2d 826 , ¶ 16 (1st Dist.2009), quoting Simmons-Harris v. Goff, 86 Ohio St.3d 1, 16 , 711 N.E.2d 203 (1999).

2016Ohio Academy of Trial Lawyers v. Sheward, 86 Ohio St.3d 451 , 1999-Ohio-123 , 715 N.E.2d 1062 ; Hoover. “[I]t is the disunity of subject matter, rather than the aggregation of topics, that causes a bill to violate the one-subject rule.” State v. Bloomer, 122 Ohio St.3d 200 , 2009-Ohio-2462 , 909 N.E.2d 1254, ¶ 49 , citing Nowak; Sheward; Hoover; and Dix. {¶16} In the instant case, we must examine the alleged violation of the one-subject rule within the context of an appropriations bill — H.B. 487.

2016Ohio Academy of Trial Lawyers v. Sheward, 86 Ohio St.3d 451 , 1999-Ohio-123 , 715 N.E.2d 1062 ; Hoover. “[I]t is the disunity of subject matter, rather than the aggregation of topics, that causes a bill to violate the one-subject rule.” State v. Bloomer, 122 Ohio St.3d 200 , 2009-Ohio-2462 , 909 N.E.2d 1254, ¶ 49 , citing Nowak; Sheward; Hoover; and Dix. {¶16} In the instant case, we must examine the alleged violation of the one-subject rule within the context of an appropriations bill — H.B. 487.

2022No. 350, 146 Ohio Laws, Part II, 3867, violated the separation-of-powers doctrine and the one-subject rule). {¶ 26} But in Arbino v. Johnson & Johnson, 116 Ohio St.3d 468 , 2007- Ohio-6948, 880 N.E.2d 420 , this court concluded that R.C. 2315.18 was constitutional on its face. 4.

2022No. 350, 146 Ohio Laws, Part II, 3867, violated the separation-of-powers doctrine and the one-subject rule). {¶ 26} But in Arbino v. Johnson & Johnson, 116 Ohio St.3d 468 , 2007- Ohio-6948, 880 N.E.2d 420 , this court concluded that R.C. 2315.18 was constitutional on its face. 4.

2016The stated purpose of the bill is “to make operating and other appropriations and to provide authorization and conditions for the operation of state programs.” We acknowledge that “[t]he analysis of the one-subject rule with respect to appropriation bills can be complicated because appropriations bills ‘encompass many items, all bound by the thread of appropriations.’” Rumpke Sanitary Landfill, Inc. v. Ohio, 184 Ohio App.3d 135 , 2009-Ohio-4888 , 919 N.E.2d 826 , ¶ 16 (1st Dist.2009), quoting Simmons-Harris v. Goff, 86 Ohio St.3d 1 , 1999-Ohio-77 , 711 N.E.2d 203 . {¶17} In the instant case, p

2013“The analysis of the one-subject rule with respect to appropriation bills can be complicated because appropriations bills ‘encompass many items, all bound by the thread of appropriations.’” Rumpke Sanitary Landfill, Inc. v. Ohio, 184 Ohio App.3d 135 , 2009-Ohio-4888 , 919 N.E.2d 826 , ¶ 16 (1st Dist.2009) quoting Simmons-Harris v. Goff, 86 Ohio St.3d 1 , 1999-Ohio-77 , 711 N.E.2d 203 . {¶41} The Ohio Supreme Court in Simmons-Harris, struck down the Ohio School Voucher Program pursuant to the one-subject rule because there was a blatant disunity between the program and the other items contained

2012No. 562 modifications to R.C. 519.211” “violated the one-subject rule of Section 15(D), Article II, Ohio Constitution” and therefore are “unconstitutional and not enforceable.” Id. at 3 and 5, citing Rumpke Sanitary Landfill, Inc. v. State, 184 Ohio App.3d 135 , 2009-Ohio-4888 , 919 N.E.2d 826 , at ¶ 18. {¶ 14} (Colerain Township had appealed that decision to this court, and we accepted discretionary review only of the following proposition of law: “A township is an interested and necessary party to a constitutional challenge brought by a property owner within the township’s jurisdiction to a

2012No. 562 modifications to R.C. 519.211” “violated the one-subject rule of Section 15(D), Article II, Ohio Constitution” and therefore are “unconstitutional and not enforceable.” Id. at 3 and 5, citing Rumpke Sanitary Landfill, Inc. v. State, 184 Ohio App.3d 135 , 2009-Ohio-4888 , 919 N.E.2d 826 , at ¶ 18. {¶ 14} (Colerain Township had appealed that decision to this court, and we accepted discretionary review only of the following proposition of law: “A township is an interested and necessary party to a constitutional challenge brought by a property owner within the township’s jurisdiction to a

1999Attorney General v. Covington, 29 Ohio St. 102 , paragraph seven of the syllabus, modified.)” {¶ 103} The one-subject rule was added to our Constitution in 1851.

1999Attorney General v. Covington, 29 Ohio St. 102 , paragraph seven of the syllabus, modified.)” The one-subject rule was added to our Constitution in 1851.

2022Dayton I, 2021-Ohio-967 , 170 N.E.3d 502, at ¶ 52 . “[T]he analysis of the one-subject rule with respect to appropriation bills can be complicated because appropriations bills ‘encompass many items, all bound by the thread of appropriations.’ ” Rumpke Sanitary Landfill, Inc. v. Ohio, 184 Ohio App.3d 135 , 2009-Ohio-4888 , 919 N.E.2d 826 , ¶ 16 (1st Dist.), quoting Simmons-Harris v. Goff, 86 Ohio St.3d 1, 16 , 711 N.E.2d 203 (1999). {¶ 30} In our view, the exclusive-jurisdiction provisions in R.C. 1901.20(A)(1) and R.C. 1907.02(C) “directly relate to the authorization and conditions of the oper

2022Dayton I, 2021-Ohio-967 , 170 N.E.3d 502, at ¶ 52 . “[T]he analysis of the one-subject rule with respect to appropriation bills can be complicated because appropriations bills ‘encompass many items, all bound by the thread of appropriations.’ ” Rumpke Sanitary Landfill, Inc. v. Ohio, 184 Ohio App.3d 135 , 2009-Ohio-4888 , 919 N.E.2d 826 , ¶ 16 (1st Dist.), quoting Simmons-Harris v. Goff, 86 Ohio St.3d 1, 16 , 711 N.E.2d 203 (1999). {¶ 30} In our view, the exclusive-jurisdiction provisions in R.C. 1901.20(A)(1) and R.C. 1907.02(C) “directly relate to the authorization and conditions of the oper

2021Cuyahoga No. 109106, 2021-Ohio-61, ¶ 66 . “[T]he analysis of the one-subject rule with respect to appropriation bills can be complicated because appropriations bills ‘encompass many items, all bound by the thread of appropriations.’ ” Rumpke Sanitary Landfill, Inc. v. Ohio, 184 Ohio App.3d 135 , 2009-Ohio-4888 , 919 N.E.2d 826 , ¶ 16 (1st Dist.2009), quoting Simmons-Harris v. Goff, 86 Ohio St.3d 1, 16 , 711 N.E.2d 203 (1999). {¶ 53} We agree with the 8th District’s conclusion in Newburgh Heights that the exclusive-jurisdiction provisions in R.C. 1901.20(A)(1) and R.C. 1907.02(C) “directly rela

2020Although we reiterated our holding in Foreman that nothing in the Ohio Constitution requires all parts of an amendment proposed by the General Assembly to share one subject, purpose, or object, id. at ¶ 30, we nonetheless followed Roahrig’s test, stating that “ ‘a proposal consists of one amendment to the Constitution only so long as each of its subjects bears some reasonable relationship to a single general object or purpose’ ” (emphasis sic), id. at ¶ 34, quoting Roahrig, 30 Ohio St.2d at 84 , 282 N.E.2d 584 .

2020Although we reiterated our holding in Foreman that nothing in the Ohio Constitution requires all parts of an amendment proposed by the General Assembly to share one subject, purpose, or object, id. at ¶ 30, we nonetheless followed Roahrig’s test, stating that “ ‘a proposal consists of one amendment to the Constitution only so long as each of its subjects bears some reasonable relationship to a single general object or purpose’ ” (emphasis sic), id. at ¶ 34, quoting Roahrig, 30 Ohio St.2d at 84 , 282 N.E.2d 584 .

2020Motors Corp., 117 Ohio St.3d 192 , 2008-Ohio-546 , 883 N.E.2d 377 , ¶ 212 (the court does not establish legislative policies or second-guess the General Assembly’s policy choices). 20. {¶ 54} The Ohio Supreme Court explains the purpose of the one-subject rule as follows: [T]he one-subject rule was added to our Constitution in 1851 as a means of placing “concrete limits on the power of the General Assembly to proceed however it saw fit in the enactment of legislation.” Specifically, “[t]he primary and universally recognized purpose of [the one-subject rule] is to prevent logrolling -- * * * the

2019No. 16AP-867, 2017-Ohio-7038, ¶ 7 . {¶ 46} The one-subject rule of the Ohio Constitution provides that "[n]o bill shall contain more than one subject, which shall be clearly expressed in its title." Article II, Section 15(D) of the Ohio Constitution.

2018Zeigler v. Zumbar , 129 Ohio St.3d 240 , 2011-Ohio-2939 , 951 N.E.2d 405 , ¶ 24. "[B]efore a statute is struck down 'it must appear beyond a reasonable doubt that the legislation and constitutional provisions are clearly incompatible.' " Id., quoting State ex rel.

2018Zeigler v. Zumbar , 129 Ohio St.3d 240 , 2011-Ohio-2939 , 951 N.E.2d 405 , ¶ 24. "[B]efore a statute is struck down 'it must appear beyond a reasonable doubt that the legislation and constitutional provisions are clearly incompatible.' " Id., quoting State ex rel.

2017City of Dublin v. State , 118 Ohio Misc.2d 18 , 769 N.E.2d 436 (Franklin Co. C.P.2002) (Hogan, J.).

2017City of Dublin v. State , 118 Ohio Misc.2d 18 , 769 N.E.2d 436 (Franklin Co. C.P.2002) (Hogan, J.).

2016Ohio Academy of Trial Lawyers v. Sheward, 86 Ohio St.3d 451 , 1999-Ohio-123 , 715 N.E.2d 1062 ; Hoover. “[I]t is the disunity of subject matter, rather than the aggregation of topics, that causes a bill to violate the one-subject rule.” State v. Bloomer, 122 Ohio St.3d 200 , 2009-Ohio-2462 , 909 N.E.2d 1254, ¶ 49 , citing Nowak; Sheward; Hoover; and Dix. {¶16} In the instant case, we must examine the alleged violation of the one-subject rule within the context of an appropriations bill — H.B. 487.

2016We accepted jurisdiction. 139 Ohio St.3d 1428 , 2014-Ohio-2725 , 11 N.E.3d 284 . {¶ 11} The parties assert seven propositions of law, which we distill to the following issues: (1) whether the prison-privatization provisions of H.B. 153 or H.B. 153 in its entirety violate the one-subject rule, (2) whether a provision in the contract for the sale of Lake Erie Correctional Facility that requires the state to pay an annual ownership fee constitutes a subsidy that violates Article VIII, Section 4 5 SUPREME COURT OF OHIO of the Ohio Constitution, and (3) whether the courts of common pleas can determ

2016We accepted jurisdiction. 139 Ohio St.3d 1428 , 2014-Ohio-2725 , 11 N.E.3d 284 . {¶ 11} The parties assert seven propositions of law, which we distill to the following issues: (1) whether the prison-privatization provisions of H.B. 153 or H.B. 153 in its entirety violate the one-subject rule, (2) whether a provision in the contract for the sale of Lake Erie Correctional Facility that requires the state to pay an annual ownership fee constitutes a subsidy that violates Article VIII, Section 4 of the Ohio Constitution, and (3) whether the courts of common pleas can determine public-employee stat

2016We accepted jurisdiction. 139 Ohio St.3d 1428 , 2014-Ohio-2725 , 11 N.E.3d 284 . {¶ 11} The parties assert seven propositions of law, which we distill to the following issues: (1) whether the prison-privatization provisions of H.B. 153 or H.B. 153 in its entirety violate the one-subject rule, (2) whether a provision in the contract for the sale of Lake Erie Correctional Facility that requires the state to pay an annual ownership fee constitutes a subsidy that violates Article VIII, Section 4 5 SUPREME COURT OF OHIO of the Ohio Constitution, and (3) whether the courts of common pleas can determ

2016We accepted jurisdiction. 139 Ohio St.3d 1428 , 2014-Ohio-2725 , 11 N.E.3d 284 . {¶ 11} The parties assert seven propositions of law, which we distill to the following issues: (1) whether the prison-privatization provisions of H.B. 153 or H.B. 153 in its entirety violate the one-subject rule, (2) whether a provision in the contract for the sale of Lake Erie Correctional Facility that requires the state to pay an annual ownership fee constitutes a subsidy that violates Article VIII, Section 4 of the Ohio Constitution, and (3) whether the courts of common pleas can determine public-employee stat

2016Id. at ¶ 51-52. {¶26} In the Cleveland decision, 2013-Ohio-1186 , 989 N.E.2d 1072 (8th Dist.), we cited to the Ohio Supreme Court’s decision in Simmons-Harris, 86 Ohio St.3d 1 , 1999-Ohio-77 , 711 N.E.2d 203 , and the First District’s decision in Rumpke, 184 Ohio App.3d 135 , 2009-Ohio-4888 , 919 N.E.2d 826 .