Arizona School Boards Ass'n, Inc. v. State
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The Supreme Court held that four legislative budget reconciliation bills (BRBs) - House Bill (HB) 2898, Senate Bill (SB) 1824, SB 1825, and SB 1819 - violated the Arizona Constitution's title requirement and were therefore void in part and that SB 1819 violated the constitutional single subject rule.
Plaintiffs - the Arizona School Boards Association and other organizations and citizens - challenged four of the eight BRBs included in the 2022 budget approved by the legislature and signed by the Governor. The trial court ruled that the challenged sections of all four BRBs violated the title requirement and that the entirety of SB 1819 violated the single subject rule. The Supreme Court affirmed, holding that the trial court did not err in ruling that the noncompliant portions of HB 2898, SB 1824, SB 1825, and SB 1819 were unconstitutional in violation of the title requirement and that SB 1819 was unconstitutional and void in violation of the single subject rule.
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