One of my favorite idle endeavors is to periodically check to see how receptive other state supreme courts have been to the "separate vote" analysis established by the Oregon Supreme Court in Armatta v. Kitzhaber. Last week, the Supreme Court of Ohio weighed in, rejecting the Armatta test in State ex rel Willke v. Taft, in favor of a more liberal test: "a proposal consists of one amendment to the Constitution only so long as each of it subjects bears some reasonable relationship to a single general object or purpose."
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