In 2012, the Louisiana Legislature passed House Bill 974, which was enacted as Act 1 of 2012 (“Act 1”). Act 1 is a comprehensive repeal and reenactment of the State’s education laws. Act 1 amended and reenacted nine statutes, enacted two statutes, and repealed twenty-nine statutes.
Teachers filed a petition for declaratory judgment against the State, alleging that Act 1 was passed in violation of the “single object” requirement of La. Const. Art. III, § 15(A) and (C).
The Supreme Court of Louisiana held that Act 1 does not violate the single object requirement of La. Const. art. III, § 15(A).
The court found that analysis of the statutory provisions encompassed by Act 1 led to the conclusion that the main general purpose of Act 1 was improving elementary and secondary education through tenure reform and performance standards based on effectiveness and that all of the provisions of Act 1 were naturally connected with, and incidental or germane to the unifying object of improving education through tenure reform and performance standards based on effectiveness.