In re Title, Ballot Title, and Submission Clause for Proposed Initiative 2025–2026 #158.

2026 CO 13. No. 25SA334. Single Subject.

March 9, 2026

The supreme court held that Initiative #158 encompasses multiple subjects in violation of article V, § 1(5.5) of the Colorado Constitution and CRS § 1-40-106.5. Initiative #158 violates the single subject requirement by combining voter approval requirements for certain fees with a change to the definition of any existing or new “fee” as that term is used in Colorado law. The court therefore reversed the actions of the Title Board and remanded this matter to the board with directions to strike the title, ballot title, and submission clause, and to return the initiative to its proponents.