Summary
The Oklahoma Supreme Court affirmed dismissal of a pre-election constitutional challenge to State Question 777, a proposed constitutional amendment concerning agricultural and ranching practices. The Court held that it should abstain from deciding the substantive constitutional issues before the legislative referendum was voted on, while leaving those challenges available after approval by the voters. The Court also reduced the deadline for filing a rehearing petition to August 11, 2016.
Topics
Practice areas
Questions Presented
- Whether the Supreme Court should address a pre-election constitutional challenge to a legislatively proposed constitutional amendment.
- Whether the district court's dismissal should be affirmed even though the district court relied on the conclusion that State Question 777 was not facially unconstitutional.
- Whether the deadline for seeking rehearing should be shortened because of exigent election-related circumstances.
Holdings
- The court abstained from addressing the substantive constitutional challenges to State Question 777 before the voters acted because the plaintiffs had not shown that placing one additional question on an already crowded general-election ballot would create the type of costly and unnecessary election that could justify judicial intervention in the legislative process.
- The Supreme Court affirmed the dismissal because the district court reached the correct result, although for the wrong reason; the proper basis was judicial abstention rather than a determination that State Question 777 was not facially unconstitutional.
- The ordinary twenty-day period for filing a petition for rehearing was reduced, requiring any petition to be filed by 4:30 p.m. on August 11, 2016.
Key quotations
“We find in this proceeding, honoring Article IV, Section 1 of the Oklahoma Constitution requires this Court to abstain from addressing the substantive issues raised by the parties.” (¶ 8)
“We will not reverse the trial court when it "reaches the correct result but for the wrong reason."” (¶ 9)
“If a pre-election challenge to the constitutionality of a legislative referendum is to be made and considered by the courts, it must be made in a timely fashion.” (Combs concurrence, ¶ 8)
Factual background
The Oklahoma Legislature passed House Joint Resolution No. 1012 in April 2015, proposing State Question 777, a constitutional amendment guaranteeing rights to engage in farming and ranching practices and restricting legislative abridgment of agricultural technology and livestock production practices absent a compelling state interest. The resolution was filed with the Secretary of State and scheduled for submission to Oklahoma voters. Plaintiffs filed suit on March 1, 2016, seeking to prevent the measure from appearing on the ballot and to have it declared facially unconstitutional.
Procedural history
The Oklahoma Legislature adopted House Joint Resolution No. 1012, referring a proposed constitutional amendment concerning agricultural and ranching practices to the voters. Plaintiffs filed a district-court action seeking a declaration that the proposed amendment was facially unconstitutional and an injunction preventing its placement on the ballot. The district court dismissed the petition, concluding that the challenge was timely and that the proposal was not facially unconstitutional. The Supreme Court affirmed, but on the ground that the court should abstain from addressing the substantive constitutional challenge before the people voted.