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In re the Title, Ballot Title and Submission Clause for 2021–2022 #16.

2021 CO 55. No. 21SA12S. Ballot Titles—Single-Subject Requirement.

June 21, 2021


A proposed initiative would eliminate certain livestock exemptions in Colorado’s criminal animal cruelty statutes, establish a safe harbor for the slaughter of livestock with various conditions, and expand the definition of “sexual act with an animal” (a type of animal cruelty). The Title Board ruled that the initiative concerns a single subject.

The Supreme Court reversed the Title Board’s actions. The initiative’s central theme is incorporating livestock into the animal cruelty statutes, but expanding the definition of “sexual act with an animal” would criminalize additional conduct regardless of whether that conduct is directed at livestock or other animals. Therefore, the initiative violates the Colorado Constitution’s single­subject requirement.

Official Colorado Supreme Court proceedings can be found at the Colorado Supreme Court website.

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