73: Hayes v. Spalding

Summary

The court held that Initiative #73 concerns a single subject because its provisions collectively address how recall elections are triggered and conducted. It nevertheless reversed the Title Board because the title omitted or obscured material changes to recall and successor-election procedures, misleadingly omitted the six-year restriction applicable to officials who resign during a recall process, and unnecessarily recited existing law. The initiative was returned to the Board for preparation of a new title satisfying the clear-title requirement.