Kenneth J. Detzner, etc. v. Harry Lee Anstead, 256 So. 3d 820

The Florida Constitution Revision Commission (CRC) approved three proposed constitutional amendments (Amendments 7, 9, and 11) that bundle multiple independent measures into single ballot questions.
Secretary of State Ken Detzner followed statutory duties and certified these CRC proposals for placement on the November 2018 ballot.
Appellees (Anstead and Barnas) filed a quo warranto petition in circuit court seeking removal of the three amendments from the ballot, arguing bundling violated statute and voters’ rights.
The circuit court granted the writ and struck the three amendments; the First District certified the question to the Florida Supreme Court as one of great public importance.
The Florida Supreme Court reversed: it held quo warranto was the wrong remedy, CRC-originated multi-subject revisions are permissible, the statutory ballot-language requirement was satisfied, and Amendment 11’s summary was not misleading.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether quo warranto was a proper vehicle to remove the Secretary’s certification	Anstead: quo warranto appropriate to challenge Secretary’s placement of defective amendments on ballot	Detzner: Secretary acted within statutory duty; quo warranto targets improper exercise of state power and is not the correct vehicle for merits challenge	Quo warranto was improper; petition failed to show Detzner exceeded authority, so relief denied
Whether CRC bundling of unrelated measures violates §101.161(1) (and related limits)	Anstead: bundling prevents a clear yes/no vote and violates statute and voting rights	Detzner: CRC amendments are not constrained by initiative single-subject rule; statute permits a yes/no vote on the whole package	Bundling of CRC-proposed amendments is permissible; statute’s yes/no format satisfied
Whether bundling implicates First Amendment right to meaningful vote	Anstead: voters forced to accept or reject unrelated measures, impairing voting rights	Detzner: no established First Amendment right to separate votes on bundled CRC proposals	Court found no demonstrated First Amendment violation; argument unsupported
Whether Amendment 11’s ballot summary is misleading about legal effect	Anstead: summary fails to inform voters of consequences, thus misleading	Detzner: summary accurately states main legal effect—removal of discriminatory alien land language	Summary adequately communicates legal effect; not misleading

Florida House of Representatives v. Crist, 999 So. 2d 601 (Fla. 2008) (quo warranto addresses improper exercise of state-derived power)
Martinez v. Martinez, 545 So. 2d 1338 (Fla. 1989) (quo warranto scope described)
Whiley v. Scott, 79 So. 3d 702 (Fla. 2011) (writ of quo warranto is proper for inquiring into improper exercise of power)
Topps Co. v. State, 865 So. 2d 1253 (Fla. 2004) (standard of review for extraordinary writs; discretionary relief)
Charter Review Commission of Orange County v. Scott, 647 So. 2d 835 (Fla. 1994) (CRC may submit multi-subject revisions because CRC process bears safeguards against logrolling)
Armstrong v. Harris, 773 So. 2d 7 (Fla. 2000) (standard for reviewing whether a proposed constitutional amendment is defective)
Askew v. Firestone, 421 So. 2d 151 (Fla. 1982) (ballot summary must advise voter sufficiently to cast an informed ballot)
Evans v. Firestone, 457 So. 2d 1351 (Fla. 1984) (ballot summary should state legal effect and no more)
Wadhams v. Board of County Commissioners, 567 So. 2d 414 (Fla. 1990) (ballot summary must represent main legal effect and ramifications)
Advisory Opinion to the Attorney General — Save Our Everglades, 636 So. 2d 1336 (Fla. 1994) (discussing logrolling concept)
Advisory Opinion to the Attorney General re Right of Citizens to Choose Health Care Providers, 705 So. 2d 563 (Fla. 1998) (noting difficulty of explaining multiple unrelated proposals in single summary)