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Ed. Freedom Pac v. Rogers (Ballot Issue)

2022-09-12

Summary

Holding. The district court's judgment invalidating the initiative petition was affirmed because the proposal violated Article 19, Section 6 of the Nevada Constitution by requiring expenditures without providing a funding source.

Education Freedom PAC sought to place a ballot initiative on Nevada's ballot that would establish education freedom accounts allowing parents to direct education spending outside the public school system. The proposal contained no funding mechanism, instead making the program contingent on future legislative appropriations. Opponents challenged the initiative as violating Nevada's constitutional ban on unfunded mandates. The district court invalidated the initiative, and Nevada's Supreme Court upheld that decision, ruling that proponents cannot circumvent the constitutional funding requirement by leaving implementation and financing to the Legislature.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether an initiative petition can defer funding responsibility to the legislature
  • Interpretation of Nevada constitutional prohibition on unfunded mandates in ballot initiatives
  • Whether conditional effectiveness based on future legislative action satisfies constitutional funding requirements

Procedural posture

Education Freedom PAC appealed a district court order granting declaratory and injunctive relief that enjoined circulation of the initiative petition and its placement on the ballot.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

majority opinion

Supreme Court

OF

NeEvADA

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IN THE SUPREME COURT OF THE STATE OF NEVADA

EDUCATION FREEDOM PAC, No. 84735

Appellant,

Vs. ‘

BEVERLY ROGERS, AN INDIVIDUAL: ~=—RPILEB

RORY REID, AN INDIVIDUAL; AND

BARBARA K. CEGAVSKE, IN HER

OFFICIAL CAPACITY AS NEVADA

SECRETARY OF STATE,

Respondents.

ORDER OF AFFIRMANCE

This is an appeal from a district court order enjoining an

initiative petition’s circulation and placement on the ballot. First Judicial District Court, Carson City; Charles M. McGee, Senior Judge.

Appellant Education Freedom PAC (EFP) seeks to place an

initiative on the ballot that would establish education freedom accounts for parents to use on their child’s education if their child is educated outside of the public school system. The initiative does not include a funding provision and instead provides that the additions proposed to NRS Chapter 394 would not become effective unless the Legislature funds them. Respondents Beverly Rogers and Rory Reid (collectively referred to as Rogers) filed a complaint for declaratory and injunctive relief challenging the initiative petition. The district court granted the requested relief, invalidating the initiative petition and enjoining EFP from circulating it for signatures and enjoining the Secretary of State from placing it on the ballot on the basis that the initiative created an unfunded mandate in violation of Article 19, Section 6 of the Nevada Constitution.

Article 19, Section 6 of the Nevada Constitution “does not

permit the proposal of any statute or statutory amendment which makes an

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Supreme Court

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appropriation or otherwise requires the expenditure of money, unless such statute or amendment also imposes a sufficient tax, not prohibited by the Constitution, or otherwise constitutionally provides for raising the necessary revenue.” See also Nev. Const. art. 19, § 2(1) (stating that the people’s power to legislate by initiative petition is “subject to the limitations of Section 6 of this Article”). In applying Article 19, Section 6, we have recognized that an initiative that “make[s] an appropriation or requires an expenditure of money” is void if it does not also provide for the necessary revenue to fund the appropriation or expenditure. Rogers v. Heller, 117 Nev. 169, 173, 18 P.3d 1034, 1036 (2001). If, like here, the district court resolves the challenge to an initiative petition in the absence of any factual dispute, our review is de novo. Helton v. Nev. Voters First PAC, 138 Nev., Adv. Op. 45, 512 P.3d 309 (2022),

We recently affirmed a district court order invalidating an initiative petition proposed by EFP that also proposed an educationfreedom-account program without a funding provision, but that petition sought to do so through an amendment to the Nevada Constitution. Education Freedom PAC v. Reid (Education Freedom I), 138 Nev., Adv. Op. 47, 512 P.38d 296 (2022). We explained in that opinion that one cannot escape the funding requirement in Article 19, Section 6 by leaving it up to the Legislature to determine how to fund the expenditures required by changes proposed in an initiative petition. Id.

With the initiative petition at issue here, EFP proposes a

statutory scheme that requires the expenditure of money but leaves to the Legislature whether and how to fund that expenditure, The petition creates a program for education freedom accounts that will require appropriations

and expenditures for the program to exist. Yet, the petition does not include

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any funding provisions. The initiative process does not permit petition proponents to propose statutes that may never take effect because they rely on the Legislature to enact legislation effectuating them. Thus, we conclude the district court properly determined that the initiative petition was void for failing to comply with Article 19, Section 6 of the Nevada Constitution.!

Accordingly, we

ORDER the judgment of the district court AFFIRMED.

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Hardesty Stiglich

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Cadish Silver

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Pickering Herndon

ce: Chief Judge, The First Judicial District Court

Hon. Charles M. McGee, Senior Judge

Hutchison & Steffen, LLC/Reno

Attorney General/Carson City

Wolf, Rifkin, Shapiro, Schulman & Rabkin, LLP

First District Court Clerk

1Tn light of our conclusion here, we need not reach the other two issues addressed in the district court’s order.

Supreme Court

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