Anantha v. Clarno

The proposed measures must satisfy the two-part framework: 1) whether a “unifying principle” can be identified, embracing a single subject, and if so 2) whether “other matters” contained within are “properly connected” to that principle. State ex rel Caleb v. Beesley, 326 Or 83, 91-93, 949 P2d 724 (1997).

Petitioners appealed the rejection of three proposed ballot measures to amend Oregon’s Forest Practices Act, by the Secretary of State (“Secretary”) because they violated the “single subject” requirement under the State Constitution. Petitioners sought judicial review, and in response to cross-motions for summary judgment, the trial court found in favor of the Secretary. On appeal, Petitioner asserted the trial court erred in finding the same violation and that each measure comported with the provision as it has been construed by the Appellate Courts. In response, the Secretary asserted the trial court correctly affirmed her rejection.  The proposed measures must satisfy the two-part framework: 1) whether a “unifying principle” can be identified, embracing a single subject, and if so 2) whether “other matters” contained within are “properly connected” to that principle. State ex rel Caleb v. Beesley, 326 Or 83, 91-93, 949 P2d 724 (1997). The Court found that the “regulation and protection of forestlands” was relatively easy to identify as a logical, unifying principle that was “properly connected." Thus, the Court held that none of the measures violated the single-subject requirement. Reversed and remanded with directions to enter judgment in favor of Petitioners.