In the Matter of the Title, Ballot Title and Submission Clause for 2015–16 73: Hayes v. Spalding

Summary

The court held that Initiative #73 concerns a single subject because its provisions are directed to the manner in which recall elections are triggered and conducted. It nevertheless reversed the Title Board because the title was insufficient and misleading: it omitted central procedural changes, failed to disclose that resignation during a recall process would trigger a six-year bar, and unnecessarily described existing law. The initiative was returned to the Title Board for a new title; no separate opinions were issued.