Forrester v. Martin
Annotate this CaseApril Forrester, individually and as a representative of all similarly situated voters-citizens, appealed from an order entered in circuit court denying Forrester's request for injunctive relief and writ of mandamus against the Arkansas Secretary of State regarding a proposed constitutional amendment. The same day the requests were denied, voters adopted the proposed amendment, now codified as amendment 89, which concerns public and private debt obligations as well as issuance of energy efficiency bonds. On appeal, Forrester argued that the circuit court erred (1) because amendment 89 violated Ark. Const. art. 19, 22 in that it actually included three separate constitutional amendments instead of the permitted one amendment, and (2) in failing to find that the Secretary of State perpetrated a manifest fraud on the voters in the wording on the ballot title by failing to meet the requirements of Ark. Code Ann 7-9-204. The Supreme Court affirmed, holding (1) there was no violation of the separate-issue requirement because all of the amendment parts were reasonably germane to each other and to the general subject of the amendment, and (2) no evidence was offered to show that there was an open and obvious fraud committed by the ballot title.
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