Clean Elections Institute, Inc. v. Brewer: The Separate Amendment Rule of the Arizona Constitution

The Clean Elections Institute court drew a clear line between the single-subject rule for statutes and the separate amendment rule for constitutional amendments. The court also reaffirmed the Kerby test for the separate amendment rule, despite some hesitation by Justice Hurwitz. The court demonstrated how to apply the test to a proposed amendment, which should provide guidance to future drafters seeking to meet the somewhat vague legal standards of the separate amendment rule.