By Evan Hamme and Andrew Appleby

The Oklahoma Supreme Court held that an initiative to amend the state’s constitution does not violate the state’s constitutional rule that a public vote to amend the constitution must address only one general subject (one general subject rule). Although the proposed constitutional amendment contains multiple sections making multiple proposals, the court held that the initiative was valid under the one general subject rule because each proposal “is germane to creating and implementing the Oklahoma Education Improvement Fund.” A three-justice dissent would have invalidated the initiative because it requires the public to vote simultaneously on numerous proposals, including raises for public school teachers and an increase to the sales and use tax rate, with public support varying for each proposal, thus resulting in the exact type of “logrolling” the one general subject rule is meant to prohibit. In re Initiative Petition No. 403 State Question No. 779, Case No. 114425 (Okla. Sup. Ct. Jan. 12, 2016).