7 Montana opinions name it 1 courts 1999–2025 3 in the last five years
The cases below were cited by Montana 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.
| Case | Followed | Cited |
|---|---|---|
Marshall v. State Ex Rel. Cooneygreen2 sentences2017See Marshall v. State, 1999 MT 33, ¶ 5 , 293 Mont. 274 , 975 P.2d 325 . ¶3 We conclude that the single-subject requirement, set forth in Article V, Section 11(3), of the Montana Constitution, applies to bills of the Legislature and not to constitutional amendments. 2017See Marshall v. State, 1999 MT 33, ¶ 5 , 293 Mont. 274 , 975 P.2d 325 . ¶3 We conclude that the single-subject requirement, set forth in Article V, Section 11(3), of the Montana Constitution, applies to bills of the Legislature and not to constitutional amendments. | 1 | 1 |
Missourians to Protect the Initiative Process v. Bluntgreen2 sentences2017See, e.g., Missourians to Protect the Initiative Process v. Blunt, 799 S.W.2d 824, 830-31 (Mo. 1990); Milwaukee Alliance Against Racist and Political Repression v. Elections Bd. of Wis., 317 N.W.2d 420, 425 (Wis. 1982); Carter v. Burson, 198 S.E.2d 151, 156 (Ga. 1973); Ohio ex rel. 2017See, e.g., Missourians to Protect the Initiative Process v. Blunt, 799 S.W.2d 824, 830-31 (Mo. 1990); Milwaukee Alliance Against Racist and Political Repression v. Elections Bd. of Wis, 317 N.W.2d 420, 425 (Wis. 1982); Carter v. Burson, 198 S.E.2d 151, 156 (Ga. 1973); Ohio ex rel. | 1 | 1 |
Carter v. Bursongreen2 sentences2017See, e.g., Missourians to Protect the Initiative Process v. Blunt, 799 S.W.2d 824, 830-31 (Mo. 1990); Milwaukee Alliance Against Racist and Political Repression v. Elections Bd. of Wis., 317 N.W.2d 420, 425 (Wis. 1982); Carter v. Burson, 198 S.E.2d 151, 156 (Ga. 1973); Ohio ex rel. 2017See, e.g., Missourians to Protect the Initiative Process v. Blunt, 799 S.W.2d 824, 830-31 (Mo. 1990); Milwaukee Alliance Against Racist and Political Repression v. Elections Bd. of Wis, 317 N.W.2d 420, 425 (Wis. 1982); Carter v. Burson, 198 S.E.2d 151, 156 (Ga. 1973); Ohio ex rel. | 1 | 1 |
Milwaukee Alliance Against Racist & Political Repression v. Elections Boardgreen2 sentences2017See, e.g., Missourians to Protect the Initiative Process v. Blunt, 799 S.W.2d 824, 830-31 (Mo. 1990); Milwaukee Alliance Against Racist and Political Repression v. Elections Bd. of Wis., 317 N.W.2d 420, 425 (Wis. 1982); Carter v. Burson, 198 S.E.2d 151, 156 (Ga. 1973); Ohio ex rel. 2017See, e.g., Missourians to Protect the Initiative Process v. Blunt, 799 S.W.2d 824, 830-31 (Mo. 1990); Milwaukee Alliance Against Racist and Political Repression v. Elections Bd. of Wis, 317 N.W.2d 420, 425 (Wis. 1982); Carter v. Burson, 198 S.E.2d 151, 156 (Ga. 1973); Ohio ex rel. | 1 | 1 |
Fugina v. Donovangreen1 sentence2017See Fugina, 104 N.W.2d at 915 . | 1 | 1 |
Californians for an Open Primary v. McPhersongreen1 sentence2017McPherson, 134 P.3d at 322-23 (“Indeed, in the few other jurisdictions that recently have embraced (explicitly or implicitly) Armatta’s interpretation of the separate-vote provision under their own constitutions, the results 1 I also concur with the Court’s statement that the single-subject requirement does not apply to constitutional amendments. | 1 | 1 |
Kerby v. Luhrsgreen2 sentences2017See Kerby, 36 P.2d at 554 (“[T]he different changes contained in the proposed amendment [did not] cover matters necessary to be dealt with in some manner, in order that the Constitution, as amended, shall constitute a consistent and workable whole on the general topic embraced in that part which is amended, and if, logically speaking, they should stand or fall as a whole, then there is but one amendment submitted.”). 2017See Kerby, 36 P.2d at 554 (“[T]he different changes contained in the proposed amendment [did not] cover matters necessary to be dealt with in some manner, in order that the Constitution, as amended, shall constitute a consistent and workable whole on the general topic embraced in that part which is amended, and if, logically speaking, they should stand or fall as a whole, then there is but one amendment submitted.”). | 1 | 1 |
Armatta v. Kitzhabergreen2 sentences1999Thus, because CI-75 has many subjects, it violates Article V, Section 11(3); because CI-75 makes more than one amendment of Montana’s Constitution, it violates Article XTV, Section 11. ¶ 13 Plaintiffs rely upon Armatta v. Kitzhaber (Or. 1998), 959 P.2d 49 . 1999See Armatta, 959 P.2d at 64 . ¶23 We hold that Article XIV, Section 11, has a substantively different meaning from that of Article V, Section 11(3) of the Montana Constitution. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Montana. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
State Ex Rel. Montana Citizens for the Preservation of Citizens' Rights v. Waltermire
green
2 sentences2014Waltermire, 224 Mont. at 277 , 729 P.2d at 1285-86 . ¶43 I would similarly decline to consider whether LR-127 violates the single-subject rule in violation of Article V, Section 11(3), of the Montana Constitution. 2014Waltermire, 224 Mont. at 277 , 729 P.2d at 1285-86 . ¶43 I would similarly decline to consider whether LR-127 violates the single-subject rule in violation of Article V, Section 11(3), of the Montana Constitution. | 2 | 2014–2014 |
Evers v. Hudson
green
2 sentences2025The single-subject requirement “relates to matters of substance . . . and not merely matters of form.” Evers, 36 Mont. at 142 , 92 P. at 464 . ¶47 We have applied strict statutory construction under Article V, Section 11(3), of the Montana Constitution when a bill contains an additional separate subject not reflected in the title. 2025The single-subject requirement “relates to matters of substance . . . and not merely matters of form.” Evers, 36 Mont. at 142 , 92 P. at 464 . ¶47 We have applied strict statutory construction under Article V, Section 11(3), of the Montana Constitution when a bill contains an additional separate subject not reflected in the title. | 1 | 2025–2025 |
State v. Cunningham
neutral
2 sentences2022The District Court did not examine this issue because it determined that the codified version of HB 702 did not contain the bill’s title, which rendered Netzer’s claim “redundant.” ¶13 Codification of a bill does not render a court’s analysis of whether a bill’s title satisfies the single-subject requirement moot or “redundant.” For many years, this Court has assessed the constitutionality of a bill’s title, despite the codification of that bill. 7 See, e.g., State v. Cunningham, 35 Mont. 547 , 90 P. 755 (1907).4 Nothing in the record or in the briefs of the respective parties justifies the di 2022The District Court did not examine this issue because it determined that the codified version of HB 702 did not contain the bill’s title, which rendered Netzer’s claim “redundant.” ¶13 Codification of a bill does not render a court’s analysis of whether a bill’s title satisfies the single-subject requirement moot or “redundant.” For many years, this Court has assessed the constitutionality of a bill’s title, despite the codification of that bill. 7 See, e.g., State v. Cunningham, 35 Mont. 547 , 90 P. 755 (1907).4 Nothing in the record or in the briefs of the respective parties justifies the di | 1 | 2022–2022 |
Montana Ass'n of Counties v. State Ex Rel. Fox
green
2 sentences2022Ass’n of Counties v. State, 2017 MT 267 , 389 Mont. 183 , 404 P.3d 733 , a party argued that the single-subject rule that Article V, Section 11(3), of the Montana Constitution applies to legislation should also extend to proposed constitutional amendments as governed by Article XIV. 2022Ass’n of Counties v. State, 2017 MT 267 , 389 Mont. 183 , 404 P.3d 733 , a party argued that the single-subject rule that Article V, Section 11(3), of the Montana Constitution applies to legislation should also extend to proposed constitutional amendments as governed by Article XIV. | 1 | 2022–2022 |
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.
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.