Wisconsin Constitution
Article IV - Legislative
Section 18 - Title of private bills.

Universal Citation: WI Const art IV § 18
No private or local bill which may be passed by the legislature shall embrace more than one subject, and that shall be expressed in the title.

Chapter 418, laws of 1977, s. 923 (48) (a) is a private or local bill enacted unconstitutionally. Soo Line R. Co. v. Transportation Dept. 101 Wis. 2d 64, 303 N.W.2d 626 (1981).

A specific prison siting provision in a budget act did not violate this section. The test for distinguishing a private or local law is established. Milwaukee Brewers v. DHSS, 130 Wis. 2d 79, 387 N.W.2d 254 (1986).

Challenged legislation, although general on its face, violated this section because the classification employed was not based on any substantial distinction between classes employed nor was it germane to purposes of the legislation. Brookfield v. Milwaukee Sewerage District, 144 Wis. 2d 896, 426 N.W.2d 591 (1988).

A bill has a single subject if all of its provisions are related to the same general purpose and are incident to that purpose. A title is insufficient only if it fails to reasonably suggest the purpose of the act or if a reading of the act with the full scope of the title in mind discloses a provision clearly outside the title. Brookfield v. Milwaukee Sewerage District, 171 Wis. 2d 400, 491 N.W.2d 484 (1992).

A 2-prong analysis for determining violations of this section is discussed. City of Oak Creek v. DNR, 185 Wis. 2d 424, 518 N.W.2d 276 (Ct. App. 1994).

Courts will not afford legislation challenged under this section a presumption of constitutionality unless the record shows that the legislature adequately considered the legislation in question. When a majority of the members of the Assembly co-sponsored a single-subject bill exempting YMCAs from property taxation before the measure was added to the budget bill and a majority of senators either co-sponsored the stand-alone bill or considered and voted for the proposal as members of the Joint Finance Committee, there was a presumption that the legislators who sponsored the bill or voted for it in committee adequately considered the proposal. Lake Country Racquet and Athletic Club, Inc. v. Morgan, 2006 WI App 25, 289 Wis. 2d 498, 710 N.W.2d 701, 04-3061.

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