Louisiana Federation of Teachers v. State of Louisiana, 14-0691 (La.10/15/14), with Justice Victory writing for the Supreme Court, reversed Judge Mike Caldwell's judgment declaring Act 1 of 2012, dealing with teacher tenure reform and performance standards, unconstitutional pursuant to La. Const. art. III, §15.
Judge Mike Caldwell held that House Bill 974 of the 2012 Regular Session of the Louisiana Legislature, which was enacted as Act 1 of 2012 ("Act 1"), violates the single object requirement for legislative bills as provided for in La. Const. art. III, §15(A). Upon review, the Supreme Court found that Act 1 did not violate the single object requirement of La. Const. art. III, §15(A).
The Supreme Court held that the single object requirement of La. Const. art. III, §15 is a restraint on the legislature aimed at preventing the dilution of the majority vote through "logrolling." The term "object" is to be broadly interpreted, and while the constitution requires unity of object, a bill may be as broad as the legislature chooses, and may contain as many provisions as the legislature chooses, as long as nothing is written into the bill except what is naturally connected with, and is incidental or germane to, its one object.
Looking first to the title, and then to the body, of Act 1, the Supreme Court gleaned that the subject of the act is elementary and secondary education, and the object of the act is improving elementary and secondary education through tenure reform and performance standards based on effectiveness. After examining the numerous provisions of Act 1, the Supreme Court determined that they all have a natural connection and are incidental and germane to that one object.
The Supreme Court reaffirmed its prior holding that in order to overturn a legislative enactment pursuant to the one-object rule, "the objections must be grave and the conflict between the statute and the constitution palpable." In this case, the Supreme Court found that plaintiffs failed to establish that such a grave and palpable conflict exists between Act 1 and the one-object rule of La. Const. art. III, §15.
Because Judge Mike Caldwell pretermitted consideration of the other constitutional arguments raised by plaintiffs, i.e., that Act 1 violates due process rights pursuant to La. Const. art. I, §2, and the Fifth and Fourteenth Amendments of the U.S. Constitution, the case was remanded for consideration of those issues.