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 contains a single subject because its provisions concern the manner in which recall elections are triggered and conducted. It nevertheless reversed the Title Board because the title failed to identify several significant changes to recall and successor-election procedures, misleadingly omitted the six-year officeholding prohibition for officials who resign during a recall, and unnecessarily recited existing law. The initiative was returned to the Title Board for a new title satisfying the clear-title requirement.