In the Matter of the Title, Ballot Title, and Submission Clause for 2013-2014 89 Douglas Kemper, Mizraim S. Cordero…

Summary

The court affirmed the Title Board’s determination that Initiative 2013-2014 No. 89 contains a single subject and that its title, ballot title, and submission clause are clear and not misleading. The court held that the initiative’s environmental-rights declaration, governmental trustee duties, and local-government authority to adopt more protective laws are all mechanisms sufficiently connected to the single purpose of creating a public right to Colorado’s environment. Justice Hobbs, joined by Chief Justice Rice, dissented, contending that the initiative combines unrelated changes to property law and state-local preemption and that the titles conceal those effects.