Mason v. Griffin-Valade

Article XVII, section 1, of the Oregon Constitution requires proposed amendments to the constitution to be submitted to voters in a manner that allows each amendment to be “voted on separately."

Respondents appealed the court's denial of their summary judgment motions and the partial granting of the plaintiff's motion regarding IP 14, an amendment aimed at changing how state legislative districts are redrawn. Plaintiffs argued that IP 14 did not meet the separate-vote requirement of the Oregon Constitution. Article XVII, section 1, of the Oregon Constitution requires proposed amendments to the constitution to be submitted to voters in a manner that allows each amendment to be “voted on separately.” To assess compliance with this requirement, the Court referenced Armatta v. Kitzhaber, 327 Or. 250 (1998), which considers whether the proposal makes multiple substantive changes and if those changes are closely related. The Court evaluated the existing constitutional provisions impacted by IP 14 and the proposed changes. The Court found that the substantive changes made in subsections (1) through (11), which detailed the creation and operation of a nonpartisan citizen committee, were closely related. The Court reasoned that it struggled to identify a logical way to separate these provisions for voter consideration, and the plaintiff did not offer a viable alternative. The Court held that IP 14 did not violate the separate-vote requirement. The decision was reversed and remanded.