single-subject rule (Arizona) · Go Syfert
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single-subject rule in Arizona

6 Arizona opinions name it 2 courts 1987–2024 1 in the last five years

The cases below were cited by Arizona 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 (9)

CaseFollowedCited
Kerby v. Luhrsgreen
ariz · 1934 · cited in 4 Arizona opinions naming this issue, 1987–2001
2 sentences

2001As we noted in another opinion filed today, “we consistently have examined initiatives challenged under the single-subject rule to determine whether their provisions are sufficiently related to a common purpose or principle that the proposal can be said to ‘constitute a consistent and workable whole on the general topic embraced,’ that, ‘logically speaking, ... should stand or fall as a whole.’ ” Korte v. Bayless, 199 Ariz. 173, 176 , at ¶ 10, 16 P.3d 200 , 203 at ¶ 10 (2001) (quoting Kerby v. Luhrs, 44 Ariz. 208, 221 , 36 P.2d 549, 554 (1934)). ¶ 3 Proposition 108 would amend Article XV of th

2001As we noted in another opinion filed today, “we consistently have examined initiatives challenged under the single-subject rule to determine whether their provisions are sufficiently related to a common purpose or principle that the proposal can be said to ‘constitute a consistent and workable whole on the general topic embraced,’ that, ‘logically speaking, ... should stand or fall as a whole.’ ” Korte v. Bayless, 199 Ariz. 173, 176 , at ¶ 10, 16 P.3d 200 , 203 at ¶ 10 (2001) (quoting Kerby v. Luhrs, 44 Ariz. 208, 221 , 36 P.2d 549, 554 (1934)). ¶ 3 Proposition 108 would amend Article XV of th

44
Korte v. Baylessgreen
ariz · 2001 · cited in 2 Arizona opinions naming this issue, 2001–2001
2 sentences

2001As we noted in another opinion filed today, “we consistently have examined initiatives challenged under the single-subject rule to determine whether their provisions are sufficiently related to a common purpose or principle that the proposal can be said to ‘constitute a consistent and workable whole on the general topic embraced,’ that, ‘logically speaking, ... should stand or fall as a whole.’ ” Korte v. Bayless, 199 Ariz. 173, 176 , at ¶ 10, 16 P.3d 200 , 203 at ¶ 10 (2001) (quoting Kerby v. Luhrs, 44 Ariz. 208, 221 , 36 P.2d 549, 554 (1934)). ¶ 3 Proposition 108 would amend Article XV of th

2001As we noted in another opinion filed today, “we consistently have examined initiatives challenged under the single-subject rule to determine whether their provisions are sufficiently related to a common purpose or principle that the proposal can be said to ‘constitute a consistent and workable whole on the general topic embraced,’ that, ‘logically speaking, ... should stand or fall as a whole.’ ” Korte v. Bayless, 199 Ariz. 173, 176 , at ¶ 10, 16 P.3d 200 , 203 at ¶ 10 (2001) (quoting Kerby v. Luhrs, 44 Ariz. 208, 221 , 36 P.2d 549, 554 (1934)). ¶ 3 Proposition 108 would amend Article XV of th

12
State v. Hansengreen
ariz · 2007 · cited in 1 Arizona opinions naming this issue, 2024–2024
1 sentence

2024See State v. Hansen, 215 Ariz. 287, 289, ¶ 6 (2007). ¶16 The Arizona Constitution requires every legislative act to “embrace but one subject and matters properly connected therewith”—the single-subject rule.

11
Arizona Chamber of Commerce & Industry v. Kileygreen
ariz · 2017 · cited in 1 Arizona opinions naming this issue, 2024–2024
1 sentence

2024See Ariz. Chamber of Com. & Indus. v. Kiley, 242 Ariz. 533, 541-42, ¶¶ 33-34 (2017).

11
In Re Lewkowitzgreen
ariz · 1950 · cited in 1 Arizona opinions naming this issue, 2024–2024
1 sentence

2024In re Lewkowitz, 70 Ariz. 325, 331-32 (1950); Taylor v. Frohmiller, 52 Ariz. 211, 215 (1938). ¶17 Until recently, the single-subject rule and the title requirement did not apply to initiatives.

11
Taylor v. Frohmillergreen
ariz · 1938 · cited in 1 Arizona opinions naming this issue, 2024–2024
1 sentence

2024In re Lewkowitz, 70 Ariz. 325, 331-32 (1950); Taylor v. Frohmiller, 52 Ariz. 211, 215 (1938). ¶17 Until recently, the single-subject rule and the title requirement did not apply to initiatives.

11
Clean Elections Institute, Inc. v. Brewergreen
ariz · 2004 · cited in 1 Arizona opinions naming this issue, 2008–2008
2 sentences

2008Further, even in applying the explicit charge of the single-subject rule, our interpretation is not “narrowly technical,” and thus “we construe legislation liberally in favor of its constitutionality.” Clean Elections Inst., Inc. v. Brewer, 209 Ariz. 241, 243, ¶ 4 , 99 P.3d 570, 572 (2004) (internal quotation marks and citations omitted).

2008Further, even in applying the explicit charge of the single-subject rule, our interpretation is not “narrowly technical,” and thus “we construe legislation liberally in favor of its constitutionality.” Clean Elections Inst., Inc. v. Brewer, 209 Ariz. 241, 243, ¶ 4 , 99 P.3d 570, 572 (2004) (internal quotation marks and citations omitted).

11
State Ex Rel. Jones v. Lockhartgreen
ariz · 1953 · cited in 1 Arizona opinions naming this issue, 2001–2001
2 sentences

2001Jones v. Lockhart, 76 Ariz. 390, 395-96 , 265 P.2d 447, 451 (1953) (upholding an initiative that would both increase the number of senators representing each county and change the representation and apportionment in the house of representatives). ¶ 11 In Kerby and our subsequent decisions, we described another formulation of the single-subject test by stating that if "the voter supporting [one proposition] would [not] reasonably be expected to support the principle of the others, then there are in reality two or more amendments to be submitted." Kerby, 44 Ariz. at 221 , 36 P.2d at 554 (emphasi

2001Jones v. Lockhart, 76 Ariz. 390, 395-96 , 265 P.2d 447, 451 (1953) (upholding an initiative that would both increase the number of senators representing each county and change the representation and apportionment in the house of representatives). ¶ 11 In Kerby and our subsequent decisions, we described another formulation of the single-subject test by stating that if "the voter supporting [one proposition] would [not] reasonably be expected to support the principle of the others, then there are in reality two or more amendments to be submitted." Kerby, 44 Ariz. at 221 , 36 P.2d at 554 (emphasi

11
Slayton v. Shumwaygreen
ariz · 1990 · cited in 1 Arizona opinions naming this issue, 2001–2001
2 sentences

2001However, we consistently have examined initiatives challenged under the single-subject rule to determine whether their provisions *204 are sufficiently related to a common purpose or principle [4] that the proposal can be said to "constitute a consistent and workable whole on the general topic embraced," that, "logically speaking, ... should stand or fall as a whole." Kerby, 44 Ariz. at 221 , 36 P.2d at 554 ; see also Slayton v. Shumway, 166 Ariz. 87, 88-89 , 800 P.2d 590, 591-92 (1990) (holding that an initiative providing ten enumerated rights of access, information, and participation to cri

2001However, we consistently have examined initiatives challenged under the single-subject rule to determine whether their provisions *204 are sufficiently related to a common purpose or principle [4] that the proposal can be said to "constitute a consistent and workable whole on the general topic embraced," that, "logically speaking, ... should stand or fall as a whole." Kerby, 44 Ariz. at 221 , 36 P.2d at 554 ; see also Slayton v. Shumway, 166 Ariz. 87, 88-89 , 800 P.2d 590, 591-92 (1990) (holding that an initiative providing ten enumerated rights of access, information, and participation to cri

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (1)

CaseCitedYears
Litchfield Elementary School District No. 79 v. Babbitt green
arizctapp · 1980
2 sentences

2024An initiative would violate the single-subject rule if it included “dissimilar and discordant subjects that by no fair intendment can be considered as having any legitimate connection with or relation to each other.” See id. at 227-28 , ¶ 34 (quoting Litchfield, 125 Ariz. at 224 ). ¶19 In Arizona School Boards Association, Inc. v. State, our supreme court held that a bill “span[ning] approximately thirty distinct subjects” violated the single-subject rule. 252 Ariz. at 228, ¶¶ 35-37.

2024An initiative would violate the single-subject rule if it included “dissimilar and discordant subjects that by no fair intendment can be considered as having any legitimate connection with or relation to each other.” See id. at 227-28 , ¶ 34 (quoting Litchfield, 125 Ariz. at 224 ). ¶19 In Arizona School Boards Association, Inc. v. State, our supreme court held that a bill “span[ning] approximately thirty distinct subjects” violated the single-subject rule. 252 Ariz. at 228, ¶¶ 35-37.

12024–2024

Where else courts name it

FL 161 (1984–2024) IL 80 (1979–2025) PA 63 (2001–2024) CA 59 (1978–2024) CO 56 (1995–2022) WA 27 (2000–2019) OR 21 (1993–2024) OH 18 (1997–2023) OK 18 (1980–2021) TX 12 (2010–2015) IA 12 (1989–2023) NV 10 (2006–2024) MT 7 (1999–2025) AZ 6 (1987–2024) MN 4 (2000–2018) NE 4 (2022–2024) AK 4 (1979–2022) UT 3 (2013–2013) WY 2 (1994–1994) KS 2 (2012–2012) MD 2 (1990–2000) SD 2 (2021–2024) MO 2 (2009–2020) AL 2 (1991–2015)

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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