The single-subject rule has been part of the California Constitution since 1948. However, the California Supreme Court had never declared that an initiative violated this requirement until Senate of California v. Jones in 1999. This ruling seemed to suggest that the court would control the ambitions of the fourth branch of government—initiative drafters. Since Jones, the California Supreme Court, in six different cases, has examined initiatives for compliance with the single-subject rule and the prohibition on constitutional revisions. By reviewing all six of these cases, this Article explains that the original hope of Jones's impact on initiatives was a mere fantasy because the single-subject rule and prohibition on constitutional revisions have again been reduced to historical artifacts.

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