single-object rule in Michigan

1999“The purpose of the single-object rule is to avoid bringing into one bill diverse subjects that have no necessary connection.” Mooahesh v Dep’t of Treasury, 195 Mich App 551, 564 ; 492 NW2d 246 (1992).

1999“The purpose of the single-object rule is to avoid bringing into one bill diverse subjects that have no necessary connection.” Mooahesh v Dep’t of Treasury, 195 Mich App 551, 564 ; 492 NW2d 246 (1992).

2026Kevorkian, 447 Mich at 456 n 20.

2026CHANGE-OF-PURPOSE CHALLENGE “When confronting a change-of-purpose challenge, a court must consider whether the change comprises a mere amendment or extension of the basic purpose of the original bill or instead introduces an entirely new and different subject matter.” Gillette, 312 Mich App at 444 . “[T]he test for determining if an amendment or substitute changes a purpose of the bill is whether -14- the subject matter of the amendment or substitute is germane to the original purpose,” which “is much like the standard for determining whether a bill is limited to a single object.” Kevorkian, 4

2026“The purpose of the single-object rule is to avoid bringing into one bill diverse subjects that have no necessary connection.” Id. at 251 .

2026In other words, the newest amendment to the SSAA, like those past, “is a means of advancing the general object” of the Act, Holland-West Ottawa-Saugatuck Consortium, 199 Mich App at 251 , and is not constitutionally violative of the single-object rule. 3.

2026Gillette Commercial Operations North America & Subsidiaries v Dep’t of Treasury, 312 Mich App 394, 441 ; 878 -13- NNW2d 891 (2015).

2026CHANGE-OF-PURPOSE CHALLENGE “When confronting a change-of-purpose challenge, a court must consider whether the change comprises a mere amendment or extension of the basic purpose of the original bill or instead introduces an entirely new and different subject matter.” Gillette, 312 Mich App at 444 . “[T]he test for determining if an amendment or substitute changes a purpose of the bill is whether -14- the subject matter of the amendment or substitute is germane to the original purpose,” which “is much like the standard for determining whether a bill is limited to a single object.” Kevorkian, 4

2026People v Carey, 382 Mich 285 , 295- 297; 170 NW2d 145 (1969). • the Legislature enacted an act that repealed multiple existing laws and included multiple regulations of different topics.

2026People v Carey, 382 Mich 285 , 295- 297; 170 NW2d 145 (1969). • the Legislature enacted an act that repealed multiple existing laws and included multiple regulations of different topics.

2015The purpose of the single-object rule is to avoid bringing into one bill diverse subjects that have no necessary connection.” H J Tucker & Assoc, Inc v Allied Chucker & Engineering Co, 234 Mich App 550, 557 ; 595 NW2d 176 (1999) (citations and quotation marks omitted).

2015The purpose of the single-object rule is to avoid bringing into one bill diverse subjects that have no necessary connection.” H J Tucker & Assoc, Inc v Allied Chucker & Engineering Co, 234 Mich App 550, 557 ; 595 NW2d 176 (1999) (citations and quotation marks omitted).

2006Commodities Export Co v Detroit, 116 Mich App 57, 71 ; 321 NW2d 842 (1982). 18 Plaintiffs sometimes refer to this provision as the “False Claims Act.” 19 Plaintiffs’ argument regarding the single-object requirement for statutes is raised for the first time on appeal.

2006Commodities Export Co v Detroit, 116 Mich App 57, 71 ; 321 NW2d 842 (1982). 18 Plaintiffs sometimes refer to this provision as the “False Claims Act.” 19 Plaintiffs’ argument regarding the single-object requirement for statutes is raised for the first time on appeal.

2006“Since the issue currently discussed was neither pleaded, nor mentioned at pretrial, nor the subject of proper amendment at trial,” we note that, “it may not be raised for the first time at final argument or on appeal.” Ewing v Heathcott, 348 Mich 250, 255 ; 83 NW2d 210 (1957).

2006“Since the issue currently discussed was neither pleaded, nor mentioned at pretrial, nor the subject of proper amendment at trial,” we note that, “it may not be raised for the first time at final argument or on appeal.” Ewing v Heathcott, 348 Mich 250, 255 ; 83 NW2d 210 (1957).

1992In Detroit Bd of Street Railway Comm’rs v Wayne Co, 18 Mich App 614, 622-623 ; 171 NW2d 669 (1969), this Court aptly summarized the single-object rule in the context of a dispute over a tax repeal: It might have been better draftsmanship to have placed the provision concerning the taxability of municipal transportation utilities in the general property tax law (where one might expect to find it) rather than in the home rule act.

1992In Detroit Bd of Street Railway Comm’rs v Wayne Co, 18 Mich App 614, 622-623 ; 171 NW2d 669 (1969), this Court aptly summarized the single-object rule in the context of a dispute over a tax repeal: It might have been better draftsmanship to have placed the provision concerning the taxability of municipal transportation utilities in the general property tax law (where one might expect to find it) rather than in the home rule act.

1983Ignoring the Supreme Court’s numerous other opinions on the subject, defendants contend that this Court is bound to use *337 what they call "the Reed test”, referring to Kent County ex rel Bd of Supervisors v Reed, 243 Mich 120 ; 219 NW 656 (1928), in applying the single-object clause.

1983Ignoring the Supreme Court’s numerous other opinions on the subject, defendants contend that this Court is bound to use *337 what they call "the Reed test”, referring to Kent County ex rel Bd of Supervisors v Reed, 243 Mich 120 ; 219 NW 656 (1928), in applying the single-object clause.

1983Thus, amendment thereof by 1976 PA 396 to include a substantive regulatory provision exempting state licensed residential facilities from zoning ordinances violates the one-object limitation of Const 1963, art 4, § 24. *12 With regard to the proper test for determining whether a particular statute violates the single-object clause, the Michigan Supreme Court noted: "Justice Cooley in People ex rel Drake v Mahaney, 13 Mich 481 (1865), says with respect to the same provision of the Constitution of 1850: " 'The history and purpose of this constitutional provision are too well understood to requir

1983The practice of bringing together into one bill subjects diverse in their nature, and having no necessary connection, with a view to combine in their favor the advocates of all, and thus secure the passage of several measures, no one of which could succeed upon its own merits, was one both corruptive of the legislator and dangerous to the state.’ Mahaney, supra, 494-495 .” Advisory Opinion on Constitutionality of 1975 PA 227 (Question 1), supra, pp 131-132.

1983The practice of bringing together into one bill subjects diverse in their nature, and having no necessary connection, with a view to combine in their favor the advocates of all, and thus secure the passage of several measures, no one of which could succeed upon its own merits, was one both corruptive of the legislator and dangerous to the state.’ Mahaney, supra, 494-495 .” Advisory Opinion on Constitutionality of 1975 PA 227 (Question 1), supra, pp 131-132.