Arizona School Boards Association, Inc. v. Arizona
Arizona School Boards Association, Inc. v. Arizona (Ariz. Sup. Ct., Jan. 6, 2022): Plaintiffs challenged four Arizona legislative budget reconciliation bills containing substantive provisions outlawing various COVID-19 intervention measures. The lower court found that the bills violated the Arizona state constitution’s title requirement and single subject rule. The single subject limits each bill to addressing only one topic, while the title requirement stands for the proposition that “a reasonable person [c]ould be expected to know what an act deals with based on its title.” After the State of Arizona appealed, the Arizona Supreme Court affirmed the lower court’s decision. Specifically, the challenged bills violated the title requirement because the bills’ titles referenced appropriations or budgetary concerns and did not indicate the presence of substantive COVID-19 measures therein. Additionally, one of the bills was found fully void as violating the single subject rule because it dealt with several varied subjects beyond the budget, including elections, emergency powers, and COVID-19. Read the full decision here.