James McLaughlin United Food & Commercial Workers Local 99 v. Ken Bennett

Summary

The concurrence agrees that Proposition 108 violates Arizona's separate-amendment requirement because its provisions concerning secrecy in public elections and secret-ballot union representation decisions are not logically interrelated. It cautions that the decisive inquiry should be whether the provisions form an integrated, workable whole requiring a single up-or-down vote, rather than whether they satisfy four potentially manipulable factors. The concurrence also explains that Proposition 108 risks logrolling by implying that rejecting the proposed union-voting right could jeopardize an existing constitutional guarantee.