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State v. Wittman

9/19/2001

provisions dealing with medical malpractice and insurance did not violate "one subject" rule of state constitution as provisions had a natural and logical connection); Smith v. Department of Ins., 507 So. 2d 1080, 1087 (Fla. 1987)(tort reform and insurance act did not violate single subject requirement, where the challenged sections addressed one primary goal: the availability of affordable liability insurance). It is clear that the provisions of chapter 97-300 are directed toward one purpose: the regulation and operation of vehicles, and of the concomitant crimes related to such regulation.


The purpose of the constitutional prohibition against a plurality of subjects in a single legislative act is to prevent a single enactment from becoming a "cloak" for dissimilar legislation having no necessary or appropriate connection with the subject matter. State v. Lee, 356 So. 2d 276, 282 (Fla. 1978). The test for determining duplicity of a subject "is whether or not the provisions of the bill are designed to accomplish separate and disassociated objects of legislative effort." Burch v. State, 558 So. 2d 1, 2 (Fla. 1990). While chapter 97-300 covers a broad range of provisions, these provisions all relate to highway safety and motor vehicles.


Article III, section 6, of the Florida Constitution is not designed to deter or impede legislation by requiring laws to be unnecessarily restrictive in their scope and operation. State ex rel. X-Cel Stores, Inc. v. Lee, 122 Fla. 685, 166 So. 568 (1936). The primary purpose of the requirements of article III, section 6 is to prevent hodge-poge or logrolling legislation. Smith v. City of St. Petersburg, 302 So. 2d 756, 757 (Fla. 1974). There was no logrolling in this legislation. The fact that several different statutes were amended does not mean that more than one subject was involved. Burch v. State, 558 So. 2d at 3. It would have been awkward and unreasonable to attempt to enact many of these provisions in separate legislation. Id.


Reversed and remanded.






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