摘要：State courts have wrestled with the single subject rule for over a century and a half. A workable legal standard for this rule has been elusive, however. A recent Illinois case addressing a controversial piece of legislation illustrates just how evasive the application of this rule can be. In Wirtz v. Quinn, the Illinois Supreme Court upheld a state “stimulus” package, which addressed topics ranging from candy taxes to video gaming in its nearly three hundred pages, because it felt that the bill fell under the subject of “capital projects.” In addition to introducing a new “smoking gun” requirement, Wirtz shows just how far a court will go in upholding legislation. This Note examines Wirtz, as well as prior single subject rule jurisprudence, and concludes that this ancient rule has modern applicability. By refocusing the rule on political accountability, the single subject rule can become a tool to promote political transparency in the wake of the Tea Party and Occupy Wall Street movements, both of which call for such transparency.
