Schwab v. Ariyoshi
58 Haw. 25, 564 P.2d 135 (1977)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A legislative act does not violate the constitutional requirement that it embrace only one subject, so long as all of its provisions are logically connected to, or are germane to, that single general subject. The act's title is constitutionally sufficient if it fairly indicates the general subject and is not calculated to mislead, even if it could be more precise.
Facts:
- The Hawaii state legislature introduced Senate Bill 1645 (S.B. 1645) with the title: 'A Bill for an Act Making Appropriations for Salaries and Other Adjustments, Including Cost Items of Collective Bargaining Agreements Covering Public Employees and Officers.'
- The bill was originally intended to ratify and fund salary increases obtained for public employees through collective bargaining agreements.
- During the legislative process, the bill was amended to include salary increases for officers in the executive, judicial, and legislative branches who were not covered by collective bargaining.
- The title of the bill was never amended to specifically mention the salary increases for these non-union officers.
- The Governor approved the bill, which became Act 58, containing four parts: Part I funded collective bargaining costs, while Parts II, III, and IV increased salaries for specific high-level government officials.
- William Schwab and Richard 'Ike' Sutton, as taxpayers, challenged the validity of the parts of the Act that provided salary increases for non-union officials.
Procedural Posture:
- William Schwab and Richard Sutton (plaintiffs) sued various Hawaii state officers in the First Circuit Court (a state trial court).
- The plaintiffs filed a motion for partial summary judgment, which the trial court denied.
- The state officers (defendants) filed a motion for summary judgment, which the trial court granted.
- Schwab and Sutton (appellants) appealed the trial court's judgment in favor of the state officers (appellees) to the Supreme Court of Hawaii.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a legislative act that both appropriates funds for collective bargaining agreements and separately adjusts salaries for non-union officers in all three branches of government violate the Hawaii Constitution's requirement that '[e]ach law shall embrace but one subject, which shall be expressed in its title'?
Opinions:
Majority - Ogata, J.
No, the act does not violate the Hawaii Constitution's single-subject requirement. The court held that Act 58 embraces one general subject—salaries for all state officers and employees—and that all of its parts are logically connected and germane to that subject. The purposes of the single-subject rule are to prevent logrolling and legislative fraud, neither of which occurred here. The court applies a liberal construction to this constitutional provision, recognizing that statutes are presumed constitutional and that an infraction must be 'plain, clear, manifest, and unmistakable.' The title, while general, fairly indicates the subject of the act to an ordinary mind and is not misleading; the word 'including' is a term of enlargement, not limitation. The court also held that alleged violations of internal legislative rules are non-justiciable under the separation of powers doctrine, so long as the constitutionally mandated procedures (e.g., three readings) were followed.
Analysis:
This decision solidifies a liberal and deferential approach to the 'one subject' rule, granting the legislature significant flexibility in drafting comprehensive bills. It establishes that as long as a rational, logical connection can be made between a bill's various provisions under a broad subject heading, courts will uphold the legislation. This precedent makes it more difficult to challenge statutes on technical grounds related to their title or the scope of their content. Furthermore, the ruling reinforces the separation of powers by deeming internal legislative procedural rules largely non-justiciable, thereby limiting judicial oversight of the legislative process to explicit constitutional mandates.
