Oregon Ballot Measure 40 (1996) and Subsequent Measures - Armatta V. Kitzhaber

The 1998 Oregon Supreme Court ruling Armatta v. Kitzhaber was a landmark decision for constitutional amendments. A similar decision in California, Jones, had recently upheld the "single subject rule," which essentially states that a single constitutional amendment measure cannot affect more than one subject in the Constitution.

But the Oregon decision went further, stating that a constitutional amendment cannot affect more than a single clause of the Constitution, even if multiple clauses affect the same subject. The decision has had a significant impact on the way initiative drafters have approached their work in the years since.