Grimaud v. Commonwealth, 581 Pa. 398

Summary

The Supreme Court of Pennsylvania upheld 1998 constitutional amendments concerning bail and the Commonwealth's right to trial by jury. The court held that the ballot questions satisfied the separate-vote requirement of Article XI, Section 1, that the Attorney General's plain-English statements were sufficient, and that the General Assembly complied with applicable constitutional amendment procedures. The court affirmed the Commonwealth Court's grant of summary judgment for the Commonwealth.

Holdings

1. A ballot question complies with Article XI, section 1 when the proposed constitutional changes are sufficiently interrelated and concern a single subject. The bail amendment concerned the single subject of bail and was properly submitted as one ballot question.
2. An amendment violates the separate-vote requirement based on its effect on other constitutional provisions only when it facially or patently affects those provisions; a merely possible or implicit effect is insufficient.
3. The Attorney General's plain-English statement satisfied 25 P.S. § 2621.1 by adequately describing the purpose, limitations, and effects of the bail amendment; the statute does not require a comprehensive treatise on every possible consequence.
4. The joint resolutions complied with Article XI, section 1 where the same proposed amendments were agreed upon in two successive legislative sessions, the operative language was identical, and any formatting defects did not make the resolutions incomprehensible.
5. The jury-trial ballot question presented a single substantive amendment and did not facially amend other constitutional provisions; therefore, it complied with Article XI, section 1.
6. Where Article XI, section 1 does not prescribe a specific internal legislative voting procedure beyond its express requirements, a challenge to the legislature's exercise of that constitutionally committed authority presents a nonjusticiable political question.

Questions Presented

1. Whether the bail amendment violated Article XI, section 1 of the Pennsylvania Constitution by combining multiple constitutional changes in a single ballot question.
2. Whether the jury-trial amendment violated Article XI, section 1 by combining multiple constitutional changes in a single ballot question.
3. Whether the Attorney General's plain-English statements adequately stated the purpose, limitations, and effects of the amendments under 25 P.S. § 2621.1.
4. Whether the joint resolutions passed in successive legislative sessions were sufficiently identical and competently formatted to satisfy Article XI, section 1.
5. Whether alleged defects in the internal legislative voting procedure presented a nonjusticiable political question.

Disposition

affirmed