In the Matter of the Titles, Ballot Titles, and Submission Clauses for Proposed Initiatives 2021–2022 #67, #115, and #128.

2022 CO 37. Nos. 22SA101, 22SA142, 22SA155.Title Board Jurisdiction—Single-Subject Requirement—Ballot Titles.

June 27, 2022

The Supreme Court considers whether three proposed initiatives violate the single-subject requirement of the Colorado Constitution, and therefore whether the Title Board lacked jurisdiction to set titles for them. Because these initiatives combine two subjects that are not necessarily or properly connected—the sale of wine at grocery stores and the home delivery of alcohol by third parties—the Court held that the initiatives violate the single-subject requirement.

Accordingly, the Court reversed the Title Board’s actions.