N.M. Const. art. IV, § 16
The subject of every bill shall be clearly expressed in its title, and no bill embracing more than one subject shall be passed except general appropriation bills and bills for the codification or revision of the laws; but if any subject is embraced in any act which is not expressed in its title, only so much of the act as is not so expressed shall be void. General appropriation bills shall embrace nothing but appropriations for the expense of the executive, legislative and judiciary departments, interest, sinking fund, payments on the public debt, public schools and other expenses required by existing laws; but if any such bill contain any other matter, only so much thereof as is hereby forbidden to be placed therein shall be void. All other appropriations shall be made by separate bills.
Comparable provisions. — Idaho Const., art. III, § 16.
Montana Const., art. V, § 11.
Utah Const., art. VI, § 22.
Wyoming Const., art. III, § 24.
When constitutionality considered. — Constitutional questions raised under this or any other section of constitution will be decided only when necessary to a disposition of the case at hand. Ratliff v. Wingfield, 1951-NMSC-071, 55 N.M. 494, 236 P.2d 725.
Objections to be grave. — This section will not be broadened in its operation by the court, as the objections to a statute should be grave, and the conflict between the statute and the constitution palpable, before the judiciary should disregard a legislative enactment upon the sole ground that it embraced more than one object, or if but one object, that it was not sufficiently expressed by the title. City of Albuquerque v. Garcia, 1973-NMSC-036, 84 N.M. 776, 508 P.2d 585, 71 A.L.R. 3d 1, rev'g 1972-NMCA-093, 84 N.M. 168, 500 P.2d 453.
Section has no retroactive effect and does not invalidate territorial acts not conforming to its requirements. State v. Elder, 1914-NMSC-074, 19 N.M. 393, 143 P. 482.
Section does not apply to municipal ordinances. State ex rel. Ackerman v. City of Carlsbad, 1935-NMSC-053, 39 N.M. 352, 47 P.2d 865.
"Codification" explained. — Real codification is to take greater latitude, and, without changing the existing system of laws, to add new laws, and to repeal old laws, both in harmony with it, so that the code will meet present exigencies and, so far as possible provide for the future. City of Raton v. Sproule, 1967-NMSC-141, 78 N.M. 138, 429 P.2d 336.
Elements of revision. — A revision of statutes implies one, more or all of the following: (1) A reexamination of existing statutes; (2) a restatement of existing statutes in a corrected or improved form; (3) the restatement may or may not include material changes; (4) all parts and provisions of the former statute or statutes that are omitted are repealed; and (5) the revision displaces and repeals the former law as it stood relating to the subject or subjects within its purview. City of Raton v. Sproule, 1967-NMSC-141, 78 N.M. 138, 429 P.2d 336; see also, 1973 Op. Att'y Gen. No. 73-12.
Revision of statutes implies reexamination of them, the word being applied to a restatement of the law in a corrected or improved form, with or without material change. City of Raton v. Sproule, 1967-NMSC-141, 78 N.M. 138, 429 P.2d 336.
Codification and revision of laws governing municipalities. — An amendment which codifies and revises the laws relating to cities, towns and villages into a municipal code as expressly stated in the title, and which in addition to collecting and rearranging prior statutes make some changes therein, omitting some matters and adding others, was valid. City of Raton v. Sproule, 1967-NMSC-141, 78 N.M. 138, 429 P.2d 336.
A. IN GENERAL.
Primary purpose of provision is to prevent fraud or surprise by means of concealed or hidden provisions in an act which the title fails to express. City of Raton v. Sproule, 1967-NMSC-141, 78 N.M. 138, 429 P.2d 336; State ex rel. State Park & Recreation Comm'n v. New Mexico State Auth., 1966-NMSC-033, 76 N.M. 1, 411 P.2d 984; Ballew v. Denson, 1958-NMSC-002, 63 N.M. 370, 320 P.2d 382; Fischer v. Rakagis, 1955-NMSC-057, 59 N.M. 463, 286 P.2d 312; State v. Ellenberger, 1981-NMSC-056, 96 N.M. 287, 629 P.2d 1216.
One of the primary purposes of the constitutional requirement is to prevent fraud or surprise upon the legislature by means of hidden or concealed provisions of which the title gives no intimation and which, therefore, through inadvertence or carelessness might be unintentionally adopted. Silver City Consol. Sch. Dist. No. 1 v. Board of Regents of N.M.W. Coll., 1965-NMSC-035, 75 N.M. 106, 401 P.2d 95.
Test of adequacy. — The true test expressed in the section is whether the title fairly gives such reasonable notice of the subject matter of the statute itself as to prevent the mischief intended to be guarded against. Bureau of Revenue v. Dale J. Bellamah Corp., 1970-NMSC-107, 82 N.M. 13, 474 P.2d 499; State ex rel. State Park & Recreation Comm'n v. New Mexico State Auth., 1966-NMSC-033, 76 N.M. 1, 411 P.2d 984; City of Albuquerque v. Campbell, 1960-NMSC-138, 68 N.M. 75, 358 P.2d 698; superseded by statute, Clark v. Ruidoso Hondo Valley Hosp., 1963-NMSC-063, 72 N.M. 9, 380 P.2d 168; State v. Ingalls, 1913-NMSC-068, 18 N.M. 211, 135 P. 1177.
Subject matter of bill to be germane to title. — If the subject matter of the bill is reasonably germane to the title of the act, it is sufficient to be valid under this section. United States Brewers Ass'n v. Director of N.M. Dep't of Alcoholic Beverage Control, 1983-NMSC-059, 100 N.M. 216, 668 P.2d 1093, appeal dismissed, 465 U.S. 1093, 104 S. Ct. 1581, 80 L. Ed. 2d 115 (1984).
What mischief to be prevented. — The mischief intended to be prevented by this section includes, hodge-podge or log-rolling legislation, surprise or fraud on the legislature or not fairly apprising the people of the subjects of legislation so that they would have an opportunity to be heard on the subject. Martinez v. Jaramillo, 1974-NMSC-069, 86 N.M. 506, 525 P.2d 866; Bureau of Revenue v. Dale J. Bellamah Corp., 1970-NMSC-107, 82 N.M. 13, 474 P.2d 499; City of Albuquerque v. Campbell, 1960-NMSC-138, 68 N.M. 75, 358 P.2d 698, superseded by statute, Clark v. Ruidoso Hondo Valley Hosp., 1963-NMSC-063, 72 N.M. 9, 380 P.2d 168.
General purpose is accomplished when law has one general object which is fairly indicated by its title. City of Raton v. Sproule, 1967-NMSC-141, 78 N.M. 138, 429 P.2d 336.
Provision does not relate to headings of articles in the code. State v. Ellenberger, 1981-NMSC-056, 96 N.M. 287, 629 P.2d 1216.
Title of statute need not be an index of everything in the act itself, but need only give notice of the subject matter of the legislation and is sufficient if, applying every reasonable intendment in favor of its validity, it may be said that the subject of the legislative enactment is expressed in its title. In re Estate of Welch, 1969-NMSC-093, 80 N.M. 448, 457 P.2d 380; Silver City Consol. Sch. Dist. No. 1 v. Board of Regents of N.M.W. Coll., 1965-NMSC-035, 75 N.M. 106, 401 P.2d 95; Aragon v. Cox, 1965-NMSC-132, 75 N.M. 537, 407 P.2d 673, overruled by State v. Chavez, 1966-NMSC-217, 77 N.M. 79, 419 P.2d 456; Gallegos v. Wallace, 1964-NMSC-224, 74 N.M. 760, 398 P.2d 982, overruled by McGeehan v. Bunch, 1975-NMSC-055, 88 N.M. 308, 540 P.2d 238.
Title of statute need not set forth details of an enactment; however, the details of a statute must be germane or related to the subject matter expressed in the title. City of Albuquerque v. Garcia, 1973-NMSC-036, 84 N.M. 776, 508 P.2d 585, 71 A L.R. 3d 1, rev’g 1972-NMCA-093, 84 N.M. 168, 500 P.2d 453; Varela v. Mounho, 1978-NMCA-086, 92 N.M. 147, 584 P.2d 194, cert. denied, 92 N.M. 180, 585 P.2d 324.
Where the "subject" of an act is children and that subject is clearly expressed, provisions within the act authorizing a change in the custody of a neglected child is a detail provided for accomplishing the legislative purpose of protecting children; such detail need not be set forth in the title of the bill to comply with the requirements of this section that the subject of every bill be clearly expressed in its title. State ex rel. Health & Social Servs. Dep't v. Natural Father, 1979-NMCA-090, 93 N.M. 222, 598 P.2d 1182.
Title need not disclose means and instrumentalities provided in the body of the act for accomplishing its purpose. Provisions reasonably necessary for attaining the object of the act embraced in the title are considered as included in the title. City of Albuquerque v. Garcia, 1973-NMSC-036, 84 N.M. 776, 508 P.2d 585, 71 A L.R. 3d 1, rev’g 1972-NMCA-093, 84 N.M. 168, 500 P.2d 453; Grant v. State, 1929-NMSC-005, 33 N.M. 633, 275 P. 95.
Scope of title of act is within discretion of legislature; it may be made broad and comprehensive, in which case the legislation under such title may be equally broad, or it may be narrow and restricted, in which case the body of the act must likewise be narrow and restricted. Gallegos v. Wallace, 1964-NMSC-224, 74 N.M. 760, 398 P.2d 982, overruled by McGeehan v. Bunch, 1975-NMSC-055, 88 N.M. 308, 540 P.2d 238.
It is primarily for the legislature to determine whether the title of an act shall be broad and general or narrow and restricted. City of Raton v. Sproule, 1967-NMSC-141, 78 N.M. 138, 429 P.2d 336.
Courts cannot enlarge scope of title; they are vested with no dispensing power. Gallegos v. Wallace, 1964-NMSC-224, 74 N.M. 760, 398 P.2d 982, overruled by McGeehan v. Bunch, 1975-NMSC-055, 88 N.M. 308, 540 P.2d 238.
Generality of title is no objection to it so long as it is not made a cover to legislation incongruous in itself, and which by no fair intendment could be considered as having a necessary or proper connection. City of Raton v. Sproule, 1967-NMSC-141, 78 N.M. 138, 429 P.2d 336.
Broader title may embrace more. — The greater and broader the title, the greater the number of particulars or of subordinate subjects which may be embraced within it. City of Raton v. Sproule, 1967-NMSC-141, 78 N.M. 138, 429 P.2d 336.
Amendatory act to be germane to earlier law. — Where an intention to amend a specific section of a prior act is announced in the title of an amendatory act, that amendatory act must be germane to the subject matter of the section sought to be amended. Bureau of Revenue v. Dale J. Bellamah Corp., 1970-NMSC-107, 82 N.M. 13, 474 P.2d 499.
Scrutinizing title of amended act. — Where an act is merely an amendment of an earlier one, the title of the earlier act is subject to scrutiny in determining whether there is compliance with the constitutional provision. State v. Sifford, 1947-NMSC-067, 51 N.M. 430, 187 P.2d 540.
What body of amending act to contain. — When it appears from title of act that certain specific provisions of another act are to be amended, body of amending act may contain only matter which is reasonably germane to subject matter of sections which are stated by title to be subject of amendment. State ex rel. Salazar v. Humble Oil & Ref. Co., 1951-NMSC-059, 55 N.M. 395, 234 P.2d 339.
Title provision of this section must be liberally construed; it is primarily for legislature to decide whether title of an act should be in broad and general terms or whether it should be narrow and restrictive. Albuquerque Bus Co. v. Everly, 1949-NMSC-058, 53 N.M. 460, 211 P.2d 127.
Presumption of validity. — In applying this test, every presumption is indulged in favor of the validity of the act. Martinez v. Jaramillo, 1974-NMSC-069, 86 N.M. 506, 525 P.2d 866; Bureau of Revenue v. Dale J. Bellamah Corp., 1970-NMSC-107, 82 N.M. 13, 474 P.2d 499.
Case by case consideration. — Each case wherein the sufficiency of the title to a legislative act is questioned must be decided on its own set of facts and circumstances. Martinez v. Jaramillo, 1974-NMSC-069, 86 N.M. 506, 525 P.2d 866; Bureau of Revenue v. Dale J. Bellamah Corp., 1970-NMSC-107, 82 N.M. 13, 474 P.2d 499.
Savings clause compared. — Constitutional enjoinder that only so much of the act as is not so expressed in the title shall be void has equal, if not greater, force than a savings clause passed as a part of a legislative act. Romero v. Tilton, 1967-NMCA-035, 78 N.M. 696, 437 P.2d 157, cert. denied, 78 N.M. 704, 437 P.2d 165 (1968), overruled by McGeehan v. Bunch, 1975-NMSC-055, 88 N.M. 308, 540 P.2d 238.
Section inapplicable to ordinances. — Ordinances of a city operating under the commission form of government enacted under authority of 14-11-22, 1953 Comp., as those of cities operating under the mayor-council form, need not be entitled under the provisions of this section. City of Clovis v. North, 1958-NMSC-077, 64 N.M. 229, 327 P.2d 305.
Determining legislative intent by title. — For the purpose of determining legislative intent, court may look to the title, and ordinarily it may be considered as a part of the act if necessary to its construction. State v. Richardson, 1944-NMSC-059, 48 N.M. 544, 154 P.2d 224.
But not to exclusion of statute proper. — Legislation should not be interpreted in the light of the title to the complete exclusion of words used in enactment proper. State ex rel. State Corp. Comm'n v. Old Abe Co., 1939-NMSC-046, 43 N.M. 367, 94 P.2d 105, 124 A.L.R. 1084.
B. TITLE ADEQUATE.
Subject incidentally affected. — As sovereign immunity was not the subject of Laws 1941, ch. 192 (former 64-25-8 and 64-25-9, 1953 Comp.) relating to liability insurance on state vehicles and actions for injuries caused by such vehicles, and was affected only incidentally, failure to mention it in the title of the act did not violate this constitutional provision. City of Albuquerque v. Garcia, 1973-NMSC-036, 84 N.M. 776, 508 P.2d 585, 71 A.L.R. 3d 1, rev'g 1972-NMCA-093, 84 N.M. 168, 500 P.2d 453.
Provisions for suit and trial are incident to annexation proceeding and failure to mention them in title of the act providing for such proceedings does not invalidate the statute. Crosthwait v. White, 1951-NMSC-003, 55 N.M. 71, 226 P.2d 477.
"State" as covering political subdivisions. — Use in title of the term "state" when the act covers "political subdivisions" thereof did not result in a failure to clearly express the subject of the legislation in the title, as such usage could not have worked surprise or fraud upon the legislature, nor could the public have failed to take notice that the components that make up the state were included in the term. City of Albuquerque v. Campbell, 1960-NMSC-138, 68 N.M. 75, 358 P.2d 698, superseded by statute, Clark v. Ruidoso-Hondo Valley Hosp., 1963-NMSC-063, 72 N.M. 9, 380 P.2d 168.
Former 5-6-17, 1953 Comp., was not unconstitutional under this section, since governing bodies of local subdivisions may reasonably be included within the term "all governing bodies of the state" if it is considered that "governing bodies of the state" means "governing bodies within the state", rather than "state governing bodies". Raton Pub. Serv. Co. v. Hobbes, 1966-NMSC-150, 76 N.M. 535, 417 P.2d 32.
"Unlawful activities". — Sections 30-31-20 to 30-31-25 NMSA 1978, which define unlawful activities relating to controlled substances and provide penalties therefor are not unconstitutional because "unlawful activities" are not mentioned in the title of the act. State v. Atencio, 1973-NMCA-110, 85 N.M. 484, 513 P.2d 1266, cert. denied, 85 N.M. 483, 513 P.2d 1265.
Abortion. — Provision of Laws 1929, § 35-310, that an attempt to produce abortion which culminates in the death of the woman shall be deemed murder in the second degree, is germane to a title denouncing "abortion". State v. Grissom, 1930-NMSC-109, 35 N.M. 323, 298 P. 666.
Aggravated battery. — Section 30-3-5 NMSA 1978 does not violate this section by providing that an aggravated battery may be either a misdemeanor or a felony, as the title clearly shows that the subject of the act is aggravated battery and that more than one penalty is provided. State v. Segura, 1973-NMCA-006, 83 N.M. 432, 492 P.2d 1295.
Drive-up windows selling alcohol. — The title of the act which enacted Subsection F (now G) of 60-7A-1 NMSA 1978 was not unconstitutionally misleading. It fairly gave reasonable notice of the subject matter of the bill - to allow local elections to determine the fate of drive-up windows vending alcohol. Thompson v. McKinley Cnty., 1991-NMSC-076, 112 N.M. 425, 816 P.2d 494.
Possession of burglar's tools. — Former 40-9-8, 1953 Comp. (Laws 1925, ch. 63) forbade the making, mending or possession of burglar's tools with criminal intent to use them or permit them to be used in the commission of a crime, not merely under circumstances evincing such an intent, and the offense prohibited was encompassed in the title of the act. State v. Lawson, 1955-NMSC-069, 59 N.M. 482, 286 P.2d 1076.
Trafficking. — Defendant's contention that 30-31-20 NMSA 1978 violated this section because the statute was concerned with trafficking in controlled substances, while the title of the act of which it was a part did not include trafficking, was without merit since the title to an enactment need not set forth details if those details are germane to its subject matter, and prohibition on trafficking was a detail germane to drugs, their administration and penalties. State v. Romero, 1974-NMCA-015, 86 N.M. 99, 519 P.2d 1180.
Unlawful payment or receipt of public funds. — Title of former 41-812, 1941 Comp., reading "An act making it a felony to receive payment from public money purportedly for personal services where such services have not been rendered; providing penalties for the commission of said felony by receipt of or disbursement of such payments" gave sufficient notice to one reading it that in the act they could expect to find a provision denouncing as a felony the paying out of public funds, or causing them to be paid out, when services were not rendered by the parties paid. State v. Aragon, 1951-NMSC-052, 55 N.M. 423, 234 P.2d 358.
Word "racketeering" did not need to appear in title to Laws 1977, ch. 215, amending the Organized Crime Act (29-9-1 to 29-9-17 NMSA 1978), nor did the title violate this section even though the 1977 amendment for the first time authorized the commission to investigate racketeering, since racketeering is reasonably germane to the subject matter of organized crime. In re Governor's Organized Crime Prevention Comm'n, 1978-NMSC-022, 91 N.M. 516, 577 P.2d 414.
Place of serving sentence. — The title to the 1961 amendment to Laws 1961, ch. 146 (54-7-15, 1953 Comp.) is sufficiently broad to give notice that the legislation prohibits the service of a part of the minimum sentence prescribed by law outside the penitentiary. Aragon v. Cox, 1965-NMSC-132, 75 N.M. 537, 407 P.2d 673, overruled by State v. Chavez, 1966-NMSC-217, 77 N.M. 79, 419 P.2d 456.
Restriction of "good time" credit. — Title to Laws 1961, ch. 146 (54-7-15, 1953 Comp.), did not fail to give adequate notice of the subject of the legislation nor offend the constitution as containing more than one subject; in phrase "to prohibit suspension or deferral of execution or imposition of sentence under certain conditions" the word "suspension" applied equally to suspension of imposition of sentence by court and suspension of its execution by the executive, and gave notice that credit for "good time" might likewise be restricted under certain conditions. Martinez v. Cox, 1965-NMSC-092, 75 N.M. 417, 405 P.2d 659.
Rights to penitentiary property. — Title to Laws 1939, ch. 55 (33-2-2 NMSA 1978 et seq.) gave ample notice that it was concerned with "titles and rights" to penitentiary property, and it was not necessary for the title of the act to set forth the source of the titles to the property which it directed to be transferred to the penitentiary. State v. Thomson, 1969-NMSC-006, 79 N.M. 748, 449 P.2d 656.
Liquor prohibition. — The title of Laws 1923, ch. 118 (since repealed), relating to prohibition of liquors, expressed the subject of that enactment with sufficient clearness to comply with this section. State v. Armstrong, 1924-NMSC-089, 31 N.M. 220, 243 P. 333.
Regulation of beer sales. — Titles of statutes regulating the sale of beer containing not more than 3.2% of alcohol, referring only to intoxicating liquors and not to nonintoxicating beverages, did not violate this section. State v. Hamm, 1933-NMSC-067, 37 N.M. 437, 24 P.2d 282. (Laws 1927, ch. 89 and Laws 1929, ch. 37, both repealed).
Amendment relating to municipal powers. — Amendatory act (former 14-39-1, 1953 Comp.), pertaining to powers of municipality to grant franchises to public utilities, which fulfilled object of constitutional provision of enabling public and legislators to form competent opinion on merits of proposed change did not violate this provision by failing to set out as a part thereof all the powers of cities as enumerated in the original act. Albuquerque Bus Co. v. Everly, 1949-NMSC-058, 53 N.M. 460, 211 P.2d 127.
Irrigation districts. — The title "An act in relation to irrigation districts" clearly expressed the subject of Laws 1919, ch. 41 (73-9-1 NMSA 1978 et seq.). Davy v. McNeill, 1925-NMSC-040, 31 N.M. 7, 240 P. 482.
Banking act. — Title 48 of the former State Banking Act (Laws 1915, ch. 67) was broad and did not violate this section. First Thrift & Loan Ass'n v. State ex rel. Robinson, 1956-NMSC-099, 62 N.M. 61, 304 P.2d 582.
Revenue Bond Act. — Title of the former Revenue Bond Act (11-10-1, 1953 Comp. et seq.) gave reasonable notice of the subject matter of the statute and did not violate this section of the constitution. State v. New Mexico State Auth., 1966-NMSC-033, 76 N.M. 1, 411 P.2d 984.
Foreclosure suits. — Laws 1933, ch. 7 (39-4-13 to 39-4-16 NMSA 1978, relating to foreclosures on judgments) is not unconstitutional on the ground that its title does not clearly express the subject of the bill and that it embraces more than one subject, contrary to the provisions of this section. Ballew v. Denson, 1958-NMSC-002, 63 N.M. 370, 320 P.2d 382.
Claims against estate. — Sections 31-8-2 and 31-8-3, 1953 Comp., relating to claims against an estate, did not offend this section. In re Estate of Welch, 1969-NMSC-093, 80 N.M. 448, 457 P.2d 380.
Cigarette tax. — Laws 1951, ch. 92, §§ 1 to 6 (repealed), did not violate this section by failing to express the subject of the act; the "subject" of the act had to do with a tax upon the sale of cigarettes in municipalities, and the fact that the levy, collection and enforcement of the tax were given to municipalities did not change the subject of the legislation, but merely provided the machinery under which the tax might be effected. Beatty v. City of Santa Fe, 1953-NMSC-110, 57 N.M. 759, 263 P.2d 697.
Succession tax. — Argument that title to Laws 1921, ch. 179, insofar as Section 17 (31-16-20, 1953 Comp.) is concerned, offends against provisions of this section because the tax provided for is a "succession tax," which would not include inter vivos transfers, even though possession and enjoyment were postponed until death, was without merit, since the legislative intent was to make the vesting of the benefits or the succession the event giving rise to the tax, and not the transfer of title. Harvey v. Vigil, 1967-NMSC-183, 78 N.M. 303, 430 P.2d 874.
Tax on property transfers. — Laws 1919, ch. 122 (since repealed), relating to taxation of property transfers, did not violate this section. State v. Gomez, 1929-NMSC-063, 34 N.M. 250, 280 P. 251.
Tax for work of commission. — The title "An act to amend Section 4 of Chapter 114 of the session laws of 1949 (46-12-4, 1953 Comp. now repealed) relating to funds for the commission on alcoholism," read against the background of the act it amends, is sufficient to advise the reader that one is going to find in it provision for levy of a tax for carrying on the work of the commission on alcoholism. Fowler v. Corlett, 1952-NMSC-055, 56 N.M. 430, 244 P.2d 1122.
Title of statute provides reasonable notice of subject matter of statute. — Where the public regulation commission (Commission) gave leave for the public service company of New Mexico (PNM) to issue energy transition bonds of up to $361,000,000 in connection with the abandonment of its interests in the San Juan generating station units one and four and to collect separate and non-bypassable energy transition charges from its customers in repayment of the bonds, pursuant to the Energy Transition Act (ETA), §§ 62-18-1 through 62-18-23 NMSA 1978, and where appellants, two organizations that represent energy consumers, claimed that the ETA violates this section because the title of the bill that created the ETA did not fairly apprise the public that the act essentially deregulates a public utility with respect to its energy transition costs, appellants' claim is without merit because the information in the title provided reasonable notice that the enactment relates to the regulation of public utilities and authorizes the Commission to approve a financing order allowing a public utility to issue bonds for the abandonment of certain generating facilities. Citizens for Fair Rates & the Env't v. NMPRC, 2022-NMSC-010.
Limitations on tax collection. — A time limitation on the collection of tax may be an incident to its collection and administration and need not be expressed in its title. Bureau of Revenue v. Dale J. Bellamah Corp., 1970-NMSC-107, 82 N.M. 13, 474 P.2d 499.
Limitations on action. — The no action provision in 37-1-27 NMSA 1978, relating to limitations on actions for defective or unsafe conditions of improvements to real property, literally is a limitation on actions that may be brought, to which the reference in the title to "limitation on actions" logically and naturally connects, providing reasonable notice of the subject matter. Howell v. Burk, 1977-NMCA-077, 90 N.M. 688, 568 P.2d 214, cert. denied, 91 N.M. 3, 569 P.2d 413.
Time for tax appeal. — Laws 1921, ch. 133, § 436 (since repealed), limiting time for appeal from tax judgment, did not violate this section. Grant v. State, 1929-NMSC-005, 33 N.M. 633, 275 P. 95.
Appeals procedure. — The title of Laws 1919, ch. 40 (16-4-19 to 16-4-21, 1953 Comp.), relating to procedure in appeals from probate court to district court, is sufficient to comply with this section. In re Ortiz's Estate, 1926-NMSC-021, 31 N.M. 427, 246 P. 908.
C. TITLE INADEQUATE.
Only part omitted from title stricken. — Even in event something has been improperly omitted from the title of an act, the saving clause in this constitutional provision, indicating that only so much of the act as is not mentioned in the title shall be void, will save the act providing for annexation of portions of counties (4-3-1 NMSA 1978 et seq.). Crosthwait v. White, 1951-NMSC-003, 55 N.M. 71, 226 P.2d 477.
Act purporting to make wholesale repeal violative of section. — The title to Laws 1947, ch. 175, reading "An act to repeal obsolete and superseded laws which are not included in the New Mexico 1941 compilation, as shown in parallel reference table volume 6 of the 1941 compilation," violated this section in that it did not clearly set out the subject of the bill. Tindall v. Bryan, 1949-NMSC-051, 54 N.M. 112, 215 P.2d 354.
Amendments not pinpointed by title. — Though title of an amendatory act could have been in general terms and yet sufficient, where there is an attempt to amend specifically by pinpointing in title of amending act the sections of the earlier act to be changed, the amendment of sections not mentioned in the title is void. State ex rel. Salazar v. Humble Oil & Ref. Co., 1951-NMSC-059, 55 N.M. 395, 234 P.2d 339.
Applicability of former guest statute to guests. — Former 64-24-1, 1953 Comp., the "guest statute," did not violate this section, which required the subject of every bill to be expressed in the title; although "guest" was not referred to in the title, reference to "passengers" gave reasonable notice of the subject, since guests in an automobile are passengers. Mwijage v. Kipkemei, 1973-NMCA-094, 85 N.M. 360, 512 P.2d 688, overruled by McGeehan v. Bunch, 1975-NMSC-055, 88 N.M. 308, 540 P.2d 238.
Application restricted to owner drivers. — Title of the guest statute, 64-24-1, 1953 Comp., is not phrased in broad or comprehensive terms, but restricts its application to owners of motor vehicles; therefore, insofar as the body of the statute limits the responsibility of nonowner drivers, it contravenes the restriction of this section. Gallegos v. Wallace, 1964-NMSC-224, 74 N.M. 760, 398 P.2d 982, overruled by McGeehan v. Bunch, 1975-NMSC-055, 88 N.M. 308, 540 P.2d 238.
Selection of jurors. — Laws 1923, ch. 131, relating to the selection of jurors, violated this section in that the title did not clearly express the subject of the act. State v. Candelaria , 1923-NMSC-019, 28 N.M. 573, 215 P. 816.
Local alcohol option. — Where the title of Laws 1971, ch. 30, which act purported in part to provide for local option elections concerning the sale of alcoholic beverages on Sunday, recited that it related to alcoholic liquors, that it repealed certain statutory provisions (unrelated to such local option elections) and pertained to "hours and days of business," the title was restrictive in nature, and as it contained nothing germane to the elections contemplated, that portion (Subsection D of former 60-10-30 NMSA 1978) was unconstitutional under this section. Martinez v. Jaramillo, 1974-NMSC-069, 86 N.M. 506, 525 P.2d 866.
School not covered in title. — The title of Laws 1921, ch. 48 (operative sections of which are now compiled as 4-11-1 to 4-11-3 NMSA 1978), creating a county and providing for bonds in aid thereof, is not broad enough to cover § 19 thereof providing for a high school, and the section is therefore void. State ex rel. Board of Educ. v. Saint, 1922-NMSC-052, 28 N.M. 165, 210 P. 573.
Limitation on collection of different tax improper. — In a bill providing for separate administration of the privilege tax on producers of oil and gas, and eliminating such producers from former Emergency School Tax Act, an attempt to place a five-year limitation on the collection of taxes under both the Oil and Gas Emergency School Tax Act (7-31-1 NMSA 1978 et seq.) and the Emergency School Tax Act was improper since such a provision was not germane to either the general subject of the bill or the express wording of its title. Bureau of Revenue v. Dale J. Bellamah Corp., 1970-NMSC-107, 82 N.M. 13, 474 P.2d 499.
Removal from ratemaking proceedings limited. — Section 63-9-14 NMSA 1978, by its terms, seems broad enough to cover removals from ratemaking proceedings, but it is part of the Telephone and Telegraph Company Certification Act and therefore can only apply to certification proceedings. Mountain States Tel. & Tel. Co. v. Corporation Comm'n, 1982-NMSC-127, 99 N.M. 1, 653 P.2d 501.
Term "subject" is to be given broad and extended meaning so as to authorize the legislature to include in one act all matters having a logical or natural connection. Silver City Consol. Sch. Dist. No. 1 v. Board of Regents of N.M.W. Coll., 1965-NMSC-035, 75 N.M. 106, 401 P.2d 95.
In considering whether a statute embraces more than one subject, the term "subject" is to be given broad and extended meaning so as to allow the legislature full scope to include in one act all matters having a logical or natural connection. Kilburn v. Jacobs, 1940-NMSC-024, 44 N.M. 239, 101 P.2d 189; Johnson v. Greiner, 1940-NMSC-017, 44 N.M. 230, 101 P.2d 183. See also, 1973 Op. Att'y Gen. No. 73-12.
More than one subject germane to issue. — When more than one subject in the act is germane to the main issue, it is constitutional. State v. Miller, 1927-NMSC-045, 33 N.M. 200, 263 P. 510.
Purpose of limitation. — This constitutional limitation was designed for the exclusion of discordant provisions having no rational or logical relation to each other. State v. Roybal, 1960-NMSC-012, 66 N.M. 416, 349 P.2d 332.
Titles liberally construed. — The court is firmly committed to the policy of applying a liberal construction to a specific title as well as to one containing broad and comprehensive language. Silver City Consol. Sch. Dist. No. 1 v. Board of Regents of N.M.W. Coll., 1965-NMSC-035, 75 N.M. 106, 401 P.2d 95.
Wholesale repeal of laws. — Laws 1947, ch. 175, entitled "An act to repeal obsolete and superseded laws which are not included in the New Mexico 1941 compilation, as shown in parallel reference table volume 6 of the 1941 compilation," violated this section because it contained more than one subject. Tindall v. Bryan, 1949-NMSC-051, 54 N.M. 112, 215 P.2d 354.
Abortion statute. — Statute denouncing attempt to produce abortion, and making such attempt, followed by death, murder in the second degree contained but one subject which was clearly expressed in its title. State v. Grissom, 1930-NMSC-109, 35 N.M. 323, 298 P. 666.
Amendment of drug and cosmetic act. — Claim that statute of which 30-31-20 NMSA 1978 is a part violated this section, because the title of the act amended sections of drug and cosmetic act and, therefore, embraced both drugs and cosmetics, was without merit. The amendments were concerned with drugs, and under the broad and extended meaning given to word "subject," statute would not be held invalid. State v. Romero, 1974-NMCA-015, 86 N.M. 99, 519 P.2d 1180.
Drug penalties. — Section 54-7-15, 1953 Comp., relating to penalties for drug offenses did not embrace more than one subject. Aragon v. Cox, 1965-NMSC-132, 75 N.M. 537, 407 P.2d 673, overruled by State v. Chavez, 1966-NMSC-217, 77 N.M. 79, 419 P.2d 456; Martinez v. Cox, 1965-NMSC-092, 75 N.M. 417, 405 P.2d 659.
Immunity from gambling penalties. — Section 44-5-14 NMSA 1978, providing immunity from punishment for gamblers who file a claim for recovery of gambling losses, does not violate this section of the constitution on grounds that more than one subject is embraced within the act. State v. Schwartz, 1962-NMSC-119, 70 N.M. 436, 374 P.2d 418.
Transportation and handling of explosives. — Statute penalizing, in one section, certain methods of transportation of explosives, and, in another section, the handling of explosives maliciously in, at or near "any building, railroad or any train or car, or any depot, stable, carhouse, theater, school, church, dwelling house or other place where human beings usually frequent, inhabit, assemble or pass" was not unconstitutional as embracing more than one subject. State v. Ornelas, 1937-NMSC-080, 42 N.M. 17, 74 P.2d 723.
Explosives and deadly weapons in penal institutions. — Laws 1941, ch. 59, § 2 (40-41-4, 1953 Comp.) was not repugnant to this section for allegedly embracing more than one subject, by prohibiting the carrying of explosives or deadly weapons within area used for confinement of prisoners, since "explosives" and "deadly weapons" were not separate subjects of the act; rather, the prohibition against introduction of explosives and deadly weapons within such institutions was a means designed to carry general purpose of the act. State v. Williams, 1962-NMSC-162, 71 N.M. 210, 377 P.2d 513.
Automobile licenses. — Laws 1912, ch. 28, repealed by Laws 1913, ch. 19, § 18, relating to automobile licenses, did not contain more than one general subject, or at least the subject was germane to that expressed in the title assuming that two subjects were included in the act. State v. Ingalls, 1913-NMSC-068, 18 N.M. 211, 135 P. 1177.
Motor vehicles and trailers. — Laws 1925, ch. 82 (since repealed), relating to motor vehicles and trailers, was not unconstitutional on ground that title embraced more than one subject, the subjects mentioned being germane to the main subject. State ex rel. Taylor v. Mirabal, 1928-NMSC-056, 33 N.M. 553, 273 P. 928, 62 A.L.R. 296.
Motor Vehicle Act. — Former Motor Vehicle Act (64-1-1, 1953 Comp. et seq.) is not constitutionally objectionable under this section in assertedly containing more than one subject; its subject was motor vehicles, and the mere inclusion of other provisions logically within the scope of the title and relating to the general subject did not violate the "one subject" restriction. State v. Roybal, 1960-NMSC-012, 66 N.M. 416, 349 P.2d 332.
Capitol building and state parks. — Laws 1939, ch. 112, § 13, relating to the capitol building and state parks, contravenes this provision. Kilburn v. Jacobs, 1940-NMSC-024, 44 N.M. 239, 101 P.2d 189; Johnson v. Greiner, 1940-NMSC-017, 44 N.M. 230, 101 P.2d 183.
Drainage law. — Drainage law (73-6-1 to 73-7-56 NMSA 1978) is not unconstitutional on the theory that Section 82 thereof (73-7-56 NMSA 1978), dealing with eminent domain relates to a different subject than the remainder of the act. In re Dexter-Greenfield Drainage Dist., 1915-NMSC-097, 21 N.M. 286, 154 P. 382.
Details of spending may be included. — This section is not to be construed to mean that nothing but bare appropriations shall be incorporated in a general appropriation bill; the details of expending the money so appropriated, which are necessarily connected with and related to the matter of providing the expenses of the government, and are so related, connected with and incidental to the subject of appropriations that they do not violate the constitution if incorporated in such general appropriation bill, may properly be included therein. State ex rel. Holmes v. State Bd. of Fin., 1961-NMSC-172, 69 N.M. 430, 367 P.2d 925.
Provisions for accounting, expenditure, and issuance of certificates not precluded. — This provision does not preclude insertion in general appropriation bill of provisions for the accounting and expenditure of the money appropriated; this would include authorization for the issue and sale of certificates of indebtedness. State ex rel. Lucero v. Marron, 1912-NMSC-037, 17 N.M. 304, 128 P. 485.
Repeal by implication of existing general legislation. — Governor properly vetoed provision in appropriation bill requiring the information processing bureau, general services department, to finance capital outlay expenses from internal services funds and specifically prohibiting use of moneys from the equipment replacement fund to fund a statutory five-year funding scheme described in the Information Systems Act (repealed). Such provision amounted to general legislation which, if left unchallenged, would repeal by implication similar funding provisions in existing general legislation. State ex rel. Coll v. Carruthers, 1988-NMSC-057, 107 N.M. 439, 759 P.2d 1380.
Limit on per diem and subsistence. — An appropriation bill which contains a limitation on per diem and subsistence for officials does not violate this section. State ex rel. Whittier v. Safford, 1923-NMSC-041, 28 N.M. 531, 214 P. 759.
Directive to relocate agency permissible. — Legislature's directive, ordering the vocational rehabilitation division of state board of education to relocate its Albuquerque office to a site more accessible to its clients, was a matter germane to and naturally connected with the expenditures of moneys, and there was no violation of the provisions of this section by including such provision in the general appropriations act. National Bldg. v. State Bd. of Educ., 1973-NMSC-053, 85 N.M. 186, 510 P.2d 510.
Appropriation to regulatory board not general legislation. — Appropriation to barber's board in 1953 general appropriation act had effect of temporarily superseding the appropriation contained in the Barbering Act (repealed) for the biennium in question; it did not constitute general legislation in an appropriation bill, as prohibited by this section. State ex rel. Prater v. State Bd. of Fin., 1955-NMSC-013, 59 N.M. 121, 279 P.2d 1042.
Inclusion of permanent policy in appropriation improper. — Part of Laws 1912, ch. 83, § 18, relating to accounting for public funds, while it bore some relation to the general appropriation act of which it was a part, provided a permanent policy thereafter to be pursued and was general legislation rendering it violative of the constitution. State ex rel. Delgado v. Sargent, 1913-NMSC-054, 18 N.M. 131, 134 P. 218.
Disposition of funds beyond biennium unlawful. — Provision of 1953 general appropriation act that "all balances remaining to the credit of any above named boards shall revert to the general fund at the end of any fiscal year" contravened this section insofar as it attempted to speak for disposition of balances remaining with the boards beyond the biennium. State ex rel. Prater v. State Bd. of Fin., 1955-NMSC-013, 59 N.M. 121, 279 P.2d 1042.
Separate bill necessary. — As this section declares that, except for the purposes which may be embraced in general appropriation bills, the moneys in the state treasury may be appropriated only by separate bills, and under N.M. Const., art. IV, § 30, such separate bill must distinctly specify the sum appropriated and the object to which it is to be applied, former 19-1-15 NMSA 1978 was unconstitutional insofar as it assumed to authorize repayment of money covered into the treasury and funded, as the property of the state, on the mere say-so of an administrative officer. McAdoo Petroleum Corp. v. Pankey, 1930-NMSC-100, 35 N.M. 246, 294 P. 322.
Title need not state all matters covered. — It is not necessary that a title specifically set forth all of the matters included in the body of an enactment. 1969 Op. Att'y Gen. No. 69-131.
Effect of detailed title. — Where the title of an act begins with a general descriptive phrase, then goes on to describe the contents in more detail, the scope of the act is limited by the more detailed description, so that a provision not contained within the detailed description is void even though it falls within the general description contained in the first phase of the title. 1973 Op. Att'y Gen. No. 73-12.
Word "appropriation" unnecessary. — Since the title of Laws 1961, ch. 194, (former 64-13-73, 64-13-75.1 and 64-13-75.2, 1953 Comp.) relating to fees for operators' and chauffeurs' licenses, and providing, inter alia, for $.25 of each fee to be retained by the division, mentions "fees," the reader is apprised that in all probability the act will also contain a provision regarding the disposition of such fees, and the act need not be invalidated for failure to use the word "appropriation" in its title. 1961 Op. Att'y Gen. No. 61-122.
Emergency clause not part of subject. — This provision does not require that the title contain a statement that a bill carries an emergency clause, since the effective date of legislation is not any part of the subject of the law; therefore Laws 1939, ch. 1, § 4, an emergency clause, made that chapter, an appropriation act, effective on its passage and approval. 1939 Op. Att'y Gen. No. 39-3001.
License photographs. — Failure to mention in the title of Laws 1961, ch. 194 (amending 64-13-73, 64-13-75.1 and 64-13-75.2, 1953 Comp. relating to operators' and chauffeurs' licenses), that photographs are to be placed on drivers' licenses does not violate this section; the photograph provision is simply a detail in the general licensing scheme and has a rational and logical connection therewith. 1961 Op. Att'y Gen. No. 61-122.
County salaries. — The purview or contents of Laws 1949, ch. 90 (former 15-43-4, 1953 Comp. relating to county officers' salaries), were germane to the title of the act. 1952 Op. Att'y Gen. No. 52-5474.
Oil Conservation Act. — The Oil Conservation Act of 1935 as amended in 1937, 1941 and 1949 was not violative of this section for failure to have the subject matter expressed clearly in the title. 1951 Op. Att'y Gen. No. 51-5397.
Veterans' tax exemption. — The title to the 1957 amendment to 72-1-14, 1953 Comp., reading: "List of soldiers entitled to exemption; Preparation by assessor; Additions," did not violate this section, since the amendment dealt only with the subject of the property tax exemption of veterans, and the method and time of obtaining such was germane to the title. 1969 Op. Att'y Gen. No. 69-131.
Only part of law embraced in title given effect. — Section 13-4-5 NMSA 1978, giving preference to materials produced within the state of New Mexico, where such materials are practicable in the construction and maintenance of public works, does not conflict with this section, even though the body of the act is broader than its title, but only so much of the act as is embraced in the title will be given effect. 1934 Op. Att'y Gen. No. 34-719.
Failure to underlineate. — This section may be violated in a case where new material, not mentioned in the title, is written into an amendatory bill with the underlineation required by Senate Rule 50, as was done in Laws 1939, ch. 173, § 1, which amended the law concerning the control of rural schools (73-9-7, 1953 Comp.), when the words "which supervisor shall be nominated by the county superintendent of schools" was inserted without being underlined. 1939 Op. Att'y Gen. No. 39-3106.
Abolishment of committee ineffective. — Because the title of Laws 1969, ch. 226, failed to contain language indicating that it was abolishing the committee on children and youth, the enactment violated the requirements of this section, and hence its attempt to repeal sections relating to that committee was void. 1969 Op. Att'y Gen. No. 69-45.
Stripping corporation commission (now public regulation commission) of control over aircraft. — Laws 1939, ch. 199, § 5 (64-1-18 NMSA 1978) violates this section since there is nothing in the title of the act of which it is a part to intimate in the least that the corporation commission (now public regulation commission) is to be stripped of its power over all aircraft. 1939 Op. Att'y Gen. No. 39-3258.
Protection of animals. — Statute entitled "An act for the protection of game and fish" cannot be transformed into an act for the protection of animals which cannot be included under the name of "game". 1915 Op. Att'y Gen. No. 15-1703.
County salaries. — Laws 1937, ch. 98 (since repealed), relating to county salaries, was unconstitutional because, inter alia, its title was probably not sufficient to cover its provisions. 1937 Op. Att'y Gen. No. 37-1652.
School boards. — Laws 1933, ch. 74 (later repealed), relating to boards of education, could not be workable in or operative for 1933, and it was unworkable and its title not sufficiently broad to meet this constitutional requirement. 1933 Op. Att'y Gen. No. 33-595.
What constitutes duplicity. — To constitute duplicity of subject, an act must embrace two or more dissimilar and discordant subjects that by no fair intendment can be considered as having any legitimate connection with or relation to each other; thus, all that is necessary under this section is that the act should embrace some one general subject. 1973 Op. Att'y Gen. No. 73-12.
Specific tuition schedules for institutions of higher education are proper subjects of an appropriations act. 1985 Op. Att'y Gen. No. 85-02.
Making of appropriations for legislature. — The state constitutional procedures applicable to the expenditure of state funds vests the authority to make appropriations in the legislature; therefore, the governor may not spend federal revenue-sharing funds without a legislative appropriation. 1973 Op. Att'y Gen. No. 73-09.
Appropriation to be for "public" purpose. — Question of whether an item of appropriation meets the "expense" test is ordinarily considered in terms of whether or not the proposed expenditure is for a "public," as distinguished from a "private" purpose; on this question, the legislature is vested with a large discretion and its determination will not be disturbed unless clearly arbitrary. 1959 Op. Att'y Gen. No. 59-79.
More than bare appropriation permissible. — This article does not require that the general appropriations bill be restricted to bare appropriations; it may contain language covering matters which are germane to and naturally and logically connected with the expenditures of the moneys provided in the bill, and only such matters as are foreign, not related to nor connected with such subject, are forbidden. 1977 Op. Att'y Gen. No. 77-11.
General appropriations bill may not reduce appropriation to administrative agency. — The legislature may not use a general appropriations bill to reduce the appropriation to an administrative agency so as to put it out of business. 1980 Op. Att'y Gen. No. 80-03.
Provisions for accounting, issuance of indebtedness must be incident to appropriation. — With a general appropriation may be included all matters germane thereto and directly connected therewith, such as provisions for the expenditure and accounting for the money, but such provisions are to have application only to matters incident to the main fact of the appropriation, and may not be considered as general legislation affecting matters not necessarily or directly connected with the appropriation legally made. 1962 Op. Att'y Gen. No. 62-88.
If the provision in the general appropriations act is so related, connected with and incidental to the subject of the appropriation and does not attempt to go beyond the current appropriation, the provision is constitutional. 1967 Op. Att'y Gen. No. 67-49.
Legislative intent determinative. — Where the legislature clearly intended the expenditure of the amount appropriated to the state board of finance to be for public purposes only, vulnerability of some particular determination by the board would be a challenge to the application of the provision in particular circumstances, and not a challenge to the constitutionality of the provision. 1959 Op. Att'y Gen. No. 59-79.
Appropriation for emergency and necessary expenses lawful. — Appropriation of $300,000 in 1959 general appropriation bill to state board of finance "for emergencies and necessary expenditures affecting the public welfare" was lawful. 1959 Op. Att'y Gen. No. 59-79.
Expenses for state educational institutions may be included in the general appropriation bill, under the authority contained in the phrase "and other expenses required by existing laws". 1912 Op. Att'y Gen. No. 12-876.
Allowing participation in public school insurance authority. — The language in Laws 1988, ch. 13, § 4 (p. 235), part of the 1988 General Appropriation Act, which allows Albuquerque public schools to participate in the public school insurance authority, clearly violates this section, which restricts the contents of general appropriation acts. 1988 Op. Att'y Gen. No. 88-58.
Legislature cannot exercise control over funds not appropriated by the general appropriations act by means of language in that act. 1967 Op. Att'y Gen. No. 67-49.
Legislature cannot impose conditions upon unappropriated funds. — The legislature does not have the power to impose conditions upon the expenditure of funds which it does not appropriate. 1980 Op. Att'y Gen. No. 80-40.
Provision referring to disposition of federal funds void. — The provision of the General Appropriations Act of 1980, Laws 1980, ch. 155, which refers to the disposition of federal funds received by the state auditor is a matter unrelated to an appropriation and is void. 1980 Op. Att'y Gen. No. 80-40.
Section not applicable to administration of federal funds. — This section, along with N.M. Const., art. IV, §§ 30 and 31, are restrictions in the objects, forms and disbursements of legislative appropriations of state funds; they have no application to a department's administration of federal or nonstate funds. 1975 Op. Att'y Gen. No. 75-10.
Section not applicable to agency's disposition of appropriation. — This section, along with N.M. Const., art. IV, §§ 30 and 31, imposes limits on the legislature's power to appropriate money and the treasurer's power to disburse it, but has nothing to do with an administrative agency's disposition of its appropriation. 1975 Op. Att'y Gen. No. 75-10.
Highway Beautification Act not appropriation. — Laws 1966, ch. 65 (67-12-1 NMSA 1978 et seq.), the Highway Beautification Act, is neither an appropriations bill nor a bill appropriating money within the meaning of this and other sections of article IV, as neither the title nor the body of the bill relates to the appropriation of funds; it is devoid of an appropriation. 1966 Op. Att'y Gen. No. 66-133.
Appropriation to several unrelated institutions unconstitutional. — A bill (not the general appropriations bill) appropriating money to three different types of institutions or associations which are not related is unconstitutional. 1937 Op. Att'y Gen. No. 37-1560.
Amendments to 22-2-8.2 NMSA 1978 made in the General Appropriation Act of 1989 were not proper, where the 1989 appropriations measure changed the effective dates for various actions under the statute and enlarged the authority of the state superintendent to waive class load requirements. The amendments constituted general legislation which, though necessary or desirable, could not constitutionally be included in an appropriations bill. 1989 Op. Att'y Gen. No. 89-26.
Conditions on amounts in miners' hospital base appropriation. — Conditions placed in the General Appropriation Bill of 1988 on the amounts in the miners' hospital base appropriation for personal services and employee benefits were valid because they were reasonably related to the amounts appropriated and did not attempt to control the details of how those amounts were expended after the appropriation was made. 1989 Op. Att'y Gen. No. 89-30.
Law reviews. — For comment, "Legislative Bodies - Conflict of Interest - Legislators Prohibited From Contracting With State," see 7 Nat. Resources J. 296 (1967).
Am. Jur. 2d, A.L.R. and C.J.S. references. — 73 Am. Jur. 2d Statutes §§ 97 to 126.
Sufficiency of title of act licensing or otherwise regulating dealers in securities or other interests or obligations of third persons, 153 A.L.R. 874.
Constitutionality of reforestation or forest conservation legislation, 13 A.L.R.2d 1095.
Validity of legislation relating to publication of legal notices, 26 A.L.R.2d 655.
82 C.J.S. Statutes §§ 212 to 220.