Chamber of Commerce v. Hon. kiley/state

Summary

The court accepted jurisdiction over the special action but denied relief, holding that Proposition 206 does not violate Arizona's Revenue Source Rule, Separate Amendment Rule, or Single Subject Rule. The Revenue Source Rule applies to expenditures expressly required by an initiative or to state actions inherently requiring nondiscretionary expenditures, but not to expenditures merely caused by discretionary state decisions or third-party contracts. The court concluded that Proposition 206 supplied a revenue source for the Industrial Commission's mandatory implementation duties, while the other two constitutional provisions do not apply to statutory initiatives.