Recognizing that state courts are beginning to review procedural challenges more rigorously, this Article attempts to provide guidance for the resolution of such cases. Part I examines the history, purposes, and standards of original purpose, single subject, and clear title restrictions, using Missouri's provisions as examples. Part I also identifies paradigmatic cases of each of the procedural violations with the hope of more sharply differentiating the three claims. Parts II through V present a case study of ten Missouri cases decided since 1994, supplemented with notable cases from other states. Part II begins with a brief description of the Missouri cases. These cases together address all three of the constitutional restrictions, and do so in more depth and variety than do the recent cases of any other single state. As such, they constitute a compact yet well-developed body of law for analysis. Part II concludes by presenting a preliminary assessment of the Missouri Supreme Court's analysis of these claims. Part III uses the Missouri cases as a basis from which to develop a framework for analysis of original purpose, single subject, and clear title claims.
Martha J. Dragich, State Constitutional Restrictions on Legislative Procedure: Rethinking the Analysis of Original Purpose, Single Subject, and Clear Title Challenges, 38 Harv. J. on Legis. 103 (2001)