Linn County v. Brown

Constitutional amendments are interpreted within the same framework as statutes, which requires looking at the text, context, and legislative history of the amendment to determine the voters' intent. State v. Sagdal, 356 Or 639, 642-43, 343 P3d 226 (2015).

Defendants appealed a judgment by the trial court granting summary judgment to plaintiffs.  Defendants assigned error to the trial court's broad interpretation of Article XI, section 15, of the Oregon Constitution.  Defendants argued that paid sick leave law was not a "program" for providing government services, but rather was a component of employee compensation; therefore the terms "program" and "service" must be considered in context of the measure.  Plaintiffs argued that Article XI, section 15, applied all "laws of general application" to everyone.  Constitutional amendments are interpreted within the same framework as statutes, which requires looking at the text, context, and legislative history of the amendment to determine the voters' intent. State v. Sagdal, 356 Or 639, 642-43, 343 P3d 226 (2015).  The Court held that the trial court erred in granting plaintiffs' motion for summary judgment based on the text, context, and legislative history of Article XI, section 15, paid sick leave is not a "program" for government services within the meaning of the unfunded programs measure.  Reversed and remanded.