The issue in this case is whether Ballot Measure 3 (2000) (Measure 3), a constitutional amendment that the people adopted pursuant to the initiative’ process, actually contains two or more constitutional amendments in violation of Article XVII, section 1, of the Oregon Constitution.1 A divided panel of the Court of Appeals held that the measure does contain two or more amendments because it makes at least two substantive changes to the constitution that are not closely related. Lincoln Interagency Narcotics Team v. Kitzhaber, 188 Or 526, 72 P3d 967 (2003). For the reasons that follow, we disagree with that conclusion and therefore reverse the decision of the Court of Appeals.
The voters adopted Measure 3 at the November 7, 2000, general election. The measure adds a new section dealing with forfeitures to Article XV of the Oregon Constitution. Measure 3 provides:
“Article XV of the Constitution of the State of Oregon is amended by a vote of the People to include the following new section:
“Section 10. The Oregon Property Protection Act of2000. (1) This section may be known and shall be cited as the ‘Oregon Property Protection Act of 2000.’
“(2) Statement of principles. The People, in the exercise of the power reserved to them under the Constitution of the State of Oregon, declare that:
“(a) A basic tenet of a democratic society is that a person is presumed innocent and should not be punished until proven guilty;
“(b) The property of a person should not be forfeited in a forfeiture proceeding by government unless and until that person is convicted of a crime involving the property; *500“(c) The value of property forfeited should be proportional to the specific conduct for which the owner of the property has been convicted; and
“(d) Proceeds from forfeited property should be used for treatment of drug abuse unless otherwise specified by law for another purpose.
“(3) Forfeitures prohibited without conviction. No judgment of forfeiture of property in a civil forfeiture proceeding by the State or any of its political subdivisions shall be allowed or entered until and unless the owner of the property is convicted of a crime in Oregon or another jurisdiction and the property is found by clear and convincing evidence to have been instrumental in committing or facilitating the crime or to be proceeds of that crime. The value of the property forfeited under the provisions of this subsection shall not be excessive and shall be substantially proportional to the specific conduct for which the owner of the property has been convicted. For purposes of this section, ‘property’ means any interest in anything of value, including the whole of any lot or tract of land and tangible and intangible personal property, including currency, instruments or securities or any other kind of privilege, interest, claim or right whether due or to become due. Nothing in this section shall prohibit a person from voluntarily giving a judgment of forfeiture.
“(4) Protection of innocent property owners. In a civil forfeiture proceeding if a financial institution claiming an interest in the property demonstrates that it holds an interest, its interest shall not be subject to forfeiture.
“In a civil forfeiture proceeding if a person claiming an interest in the property, other than a financial institution or a defendant who has been charged with or convicted of a crime involving that property, demonstrates that the person has an interest in the property, that person’s interest shall not be subject to forfeiture unless:
“(a) The forfeiting agency proves by clear and convincing evidence that the person took the property or the interest with the intent to defeat the forfeiture; or
“(b) A conviction under subsection (3) is later obtained against the person.
*501“(5) Exception for unclaimed property and contraband. Notwithstanding the provisions of subsection (3) of this section, if, following notice to all persons known to have an interest or who may have an interest, no person claims an interest in the seized property or if the property is contraband, a judgment of forfeiture may be allowed and entered without a criminal conviction. For purposes of this subsection, ‘contraband’ means personal property, articles or things, including but not limited to controlled substances or drug paraphernalia, that a person is prohibited by Oregon statute or local ordinance from producing, obtaining or possessing.
“(6) Law enforcement seizures unaffected. Nothing in this section shall be construed to affect the temporary seizure of property for evidentiary, forfeiture, or protective purposes, or to alter the power of the Governor to remit fines or forfeitures under Article V, Section 14, of this Constitution.
“(7) Disposition of property and proceeds to drug treatment. Any sale of forfeited property shall be conducted in a commercially reasonable manner. Property or proceeds forfeited under subsections (3), (5), or (8) of this section shall not be used for law enforcement purposes but shall be distributed or applied in the following order:
“(a) To the satisfaction of any foreclosed liens, security interests and contracts in the order of their priority;
“(b) To the State or any of its political subdivisions for actual and reasonable expenses related to the costs of the forfeiture proceeding, including attorney fees, storage, maintenance, management, and disposition of the property incurred in connection with the sale of any forfeited property in an amount not to exceed twenty-five percent of the total proceeds in any single forfeiture;
“(c) To the State or any of its political subdivisions to be used exclusively for drug treatment, unless another disposition is specially provided by law.
“(8) State and federal sharing. The State of Oregon or any of its political subdivisions shall take all necessary steps to obtain shared property or proceeds from the United States Department of Justice resulting from a forfeiture. *502Any property or proceeds received from the United States Department of Justice by the State of Oregon or any of its political subdivisions shall be applied as provided in subsection (7) of this section.
“(9) Restrictions on State transfers. Neither the State of Oregon, its political subdivisions, nor any forfeiting agency shall transfer forfeiture proceedings to the federal government unless a state court has affirmatively found that:
“(a) The activity giving rise to the forfeiture is interstate in nature and sufficiently complex to justify the transfer;
“(b) The seized property may only be forfeited under federal law; or
“(c) Pursuing forfeiture under state law would unduly burden the state forfeiting agencies.
“(10) Penalty for violations. Any person acting under color of law, official title or position who takes any action intending to conceal, transfer, withhold, retain, divert or otherwise prevent any proceeds, conveyances, real property, or any things of value forfeited under the law of this State or the United States from being applied, deposited or used in accordance with subsections (7), (8) or (9) of this section shall be subject to a civil penalty in an amount treble the value of the forfeited property concealed, transferred, withheld, retained or diverted. Nothing in this subsection shall be construed to impair judicial immunity if otherwise applicable.
“(11) Reporting requirement. All forfeiting agencies shall report the nature and disposition of all property and proceeds seized for forfeiture or forfeited to a State asset forfeiture oversight committee that is independent of any forfeiting agency. The asset forfeiture oversight committee shall generate and make available to the public an annual report of the information collected. The asset forfeiture oversight committee shall also make recommendations to ensure that asset forfeiture proceedings are handled in a manner that is fair to innocent property owners and interest holders.
*503“(12) Severability. If any part of this section or its application to any person or circumstance is held to be invalid for any reason, then the remaining parts or applications to any persons or circumstances shall not be affected but shall remain in full force and effect.”
(Emphasis in original.)
Measure 3 follows the unfortunate practice, sometimes questioned, of inserting provisions in the state constitution that have more in common, both in appearance and in substance, with legislation than with constitutional amendments. See Olsen v. State ex rel Johnson, 276 Or 9, 19, 554 P2d 139 (1976) (recognizing practice). The measure begins, for example, by stating that it “may be known and shall be cited as the ‘Oregon Property Protection Act of 2000’ ” — a designation more typically associated with legislation than with constitutional amendments.2 See Christ/Tauman v. Myers, 339 Or 494, 499, 123 P3d 271 (2005) (explaining that “[a]cts are different from constitutional amendments”). The fact that Measure 3 adds almost two pages of provisions dealing with forfeitures to a single section of the Oregon Constitution is consistent with that designation. The measure imposes various procedural and substantive limitations on forfeiture proceedings, establishes priorities for and limitations on the distribution of forfeiture proceeds (including proceeds from federal forfeiture proceedings that are available to the state), creates a state agency to monitor and report on forfeitures, and provides a civil penalty for violating its provisions.
After the people adopted Measure 3, plaintiffs Lincoln Interagency Narcotics Team (LINT) and Lincoln County filed a declaratory judgment action against the Governor, the Secretary of State, and the State of Oregon (collectively “the state”), seeking a declaration that the measure contained two or more amendments in violation of Article XVII, section 1. Alternatively, plaintiffs sought a declaration that Measure 3 embraced more than one subject, in violation *504of Article IV, section l(2)(d), of the Oregon Constitution.3 The chief petitioners of Measure 3 (interveners) intervened in defense of the measure.4 On cross-motions for summary judgment, the trial court ruled that Measure 3 contained only one amendment to the constitution and embraced only a single subject, and entered judgment accordingly.
Plaintiff LINT appealed, and a divided panel of the Court of Appeals reversed. The majority concluded that, under the analysis in Armatta v. Kitzhaber, 327 Or 250, 959 P2d 49 (1998), subsections (3) and (7) of Measure 3 made two substantive changes to the constitution that were not closely related. Lincoln Interagency Narcotics Team, 188 Or App at 538-43, 546-48.
Judge Armstrong dissented. In his view, the majority’s decision failed to give effect to this court’s decisions in Baum v. Newbry et al., 200 Or 576, 267 P2d 220 (1954), and Hartung v. Bradbury, 332 Or 570, 33 P3d 972 (2001). The dissent reasoned that the changes that Measure 3 made to the Oregon Constitution were as closely related as the changes that the court upheld in Baum and that they were the type of changes that “would commonly be placed in a single section of the constitution.” Id. at 570 (Armstrong, J., dissenting). It followed, the dissent concluded, that Measure 3 did not contain two or more amendments to the constitution. Id. We allowed the state’s petition for review to consider this recurring issue.
As noted, Article XVII, section 1, of the Oregon Constitution provides that, “[w]hen two or more amendments shall be submitted in the manner aforesaid to the voters of this state at the same election, they shall be submitted so that each amendment shall be voted on separately.” In Armatta, this court undertook, for the first time, a comprehensive examination of the meaning of that separate-vote requirement.5 Following the methodology in Priest v. Pearce, *505314 Or 411, 840 P2d 65 (1992), the court considered the wording of Article XVII, section 1, its history, and the cases interpreting it. See Armatta, 327 Or at 256-77 (undertaking that analysis). The court drew three conclusions from those sources. First, looking primarily to the debates on the Indiana Constitution, the court concluded that the word “amendment” refers to a specific or particular change to the constitution. Id. at 265-66; see also Lehman v. Bradbury, 333 Or 231, 239, 37 P3d 989 (2002) (drawing that conclusion from Armatta). Citing historical examples, the court observed that “a single ‘amendment,’ such as one concerning the establishment of a state bank or the rights of married women, was intended to encompass a particular constitutional change.” Armatta, 327 Or at 265-66.
Second, the court concluded that the separate-vote requirement for initiated laws and constitutional amendments imposes a more restrictive test than the single-subject requirement set out in Article IV, section l(2)(d), of the Oregon Constitution. Id. at 276. The court noted that the single-subject requirement focuses on the content of a proposed law or amendment, while the separate-vote requirement focuses on the “potential change to the existing constitution” and the degree to which “a proposed amendment would modify the existing constitution.” Id. (emphases in original). More significantly, the court explained that
“the separate-vote requirement applies to only constitutional amendments, while the single-subject requirement applies equally to constitutional amendments and legislation. It follows, we believe, that the separate-vote requirement of Article XVII, section 1, imposes a narrower requirement than does the single-subject requirement of Article IV, section l(2)(d). Such a reading of the separate-vote requirement makes sense, because the act of amending the constitution is significantly different from enacting or amending legislation. * * * Indeed, because the separate-vote requirement is concerned only with a change to the fundamental law, the notion that the people should be able to vote separately upon each separate amendment should come as no surprise. In short, the requirement serves as a *506safeguard that is fundamental to the concept of a constitution.”
Id. (emphases in original; citation omitted).
Third (and most important to the task we face in this case), the court recognized that, although the separate-vote requirement is more restrictive than the single-subject requirement, it is not inflexible. The court recognized that two or more changes will not violate the separate-vote requirement if the relationship between the two changes is a close one. Id. at 277. As the court phrased the test, the question whether a measure contains two or more amendments in violation of Article XVII, section 1, turns on whether the measure, if adopted, “would make two or more changes to the constitution that are substantive and that are not closely related.” Id. Or, as this court recently summarized the Armatta methodology:
“To implement th[e] * * * requirement of [Article XVII, section 1], we do not search simply for a unifying thread to create a common theme, thought, or purpose from a melange of proposed constitutional changes. Instead, we inquire whether, if adopted, a proposal would make two or more changes to the constitution that are substantive and are not closely related. If so, the proposal violates the separate-vote requirement of Article XVII, section 1, because it would prevent voters from expressing their opinions as to each proposed change separately.”
Meyer v. Bradbury, 341 Or 288, 296-97, 142 P3d 1031 (2006).
In Armatta, the court held that the measure at issue there contained multiple substantive changes to the constitution and that those changes were not closely related. More specifically, the court identified two pairs of changes to the constitution that were not closely related:
“For example, the right of all people to be free from unreasonable searches and seizures under Article I, section 9, has virtually nothing to do with the right of the criminally accused to have a unanimous jury verdict rendered in a murder case under Article I, section 11. The two provisions involve separate constitutional rights, granted to different groups of persons. Similarly, the right of the criminally accused to bail by sufficient sureties under Article I, section *50714, bears no relation to legislation concerning the qualifications of jurors in criminal cases under Article VII (Amended), section 5(l)(a).”
Id. at 283-84.
In deciding whether the changes in Armatta were closely related, the court “considered both the relationship among the constitutional provisions affected by [the measure] and the relationship of the constitutional changes that were made in those provisions to one another.” See Lehman, 333 Or at 245 (explaining Armatta). In some cases, however, the court has looked solely to the relationship between two or more changes that a measure effects in holding that the changes were not closely related. See Swett v. Bradbury, 333 Or 597, 608, 43 P3d 1094 (2002) (employing that methodology). But, beyond identifying those two methodologies for testing whether constitutional changes are closely related, the court has declined one party’s proposal to reformulate the “closely related” standard announced in Armatta. See Lehman, 333 Or at 242 (explaining that party’s proposed reformulation of “closely related” test would not advance inquiry). Indeed, this court has observed recently that, “if this court has written little on the subject, it is because there have been few instances in which the constitutional changes before the court presented a close question on that issue.” Meyer, 341 Or at 300.
Finally, we add to the foregoing overview of our “separate-vote” jurisprudence the following observation from Swett, which (as will be seen) is particularly applicable here:
“Ordinarily, we begin any separate-vote inquiry by identifying the changes, both explicit and implicit, that the ballot measure purports to make to the Oregon Constitution. We then determine if those changes are substantive. If they are, we then determine if those substantive changes are ‘closely related.’ In Lehman, we described that analytical process this way:
“ ‘* * * First, we examine the relationship among the constitutional provisions that the measure affects * * *. If the affected provisions of the existing constitution themselves are not related, then it is likely that changes *508to those provisions will offend the separate-vote requirement. * * * [T]he fact that a proposed amendment asks the people, in one vote, substantively to change multiple provisions of the Oregon Constitution that are not themselves related is one indication that the proposed amendment might violate the separate-vote requirement.
“ ‘Next, we must consider the constitutional changes themselves. That is, * * * we must determine whether the changes made to those * * * constitutional provisions are closely related. If they are closely related, the measure under consideration survives scrutiny under Article XVII, section 1. If they are not, it does not.’
“The foregoing statement from Lehman was descriptive, not prescriptive. That is, it is equally valid analytically to start the inquiry by focusing on the changes themselves. This case illustrates the point. We need not discuss each of the steps described above, because the parties’ arguments narrow the focus of our inquiry.* * *”
Swett, 333 Or at 607 (citations omitted) (quoting Lehman, 333 Or at 246 (ellipses and modifications in original)). As we shall identify, the parties to the present case have, like the parties in Swett, attempted to short-cut the process here by focusing their arguments primarily on the issue whether the multiple changes that Measure 3 effects are “closely related.”
We turn to the various provisions of Measure 3. The parties focus, as the Court of Appeals did, on two subsections in Measure 3 — subsection (3) and subsection (7). The parties agree that subsection (3) makes three substantive changes to the Oregon Constitution: (1) it makes a criminal conviction a prerequisite for a civil forfeiture; (2) it requires that proof of the elements necessary to establish forfeiture be by clear and convincing evidence; and (3) it provides that the value of the forfeited property “shall not be excessive and shall be substantially proportional to the specific conduct for which the owner of the property has been convicted.” The parties disagree, however, as to whether those three substantive changes are closely related.
For the sake of the present argument, we will assume that the foregoing three statements in fact do reflect *509three separate substantive changes to the Oregon Constitution. However, that assumption does not assist plaintiffs in their claim that Measure 3 violates the separate-vote requirement of Article XVII, section 1. That is so because the identified changes all are “closely related.”
Our analysis in that regard ordinarily would begin with an examination of the relationship among any existing constitutional provisions that the three identified changes affect to determine if those provisions themselves are closely related. See 341 Or at 507-08 (quoting Swett). However, we find that the three changes are additions to the Oregon Constitution and have no effect on any existing constitutional provision in that document. The first change — making criminal conviction a prerequisite of civil forfeiture — requires no discussion in that regard: Neither party has made any claim that the change relates to any existing provision in the state or federal constitution. As to the second change — requiring forfeitures to be proved by clear and convincing evidence— there is some suggestion that the change alters constitutional provisions pertaining to standards of proof in criminal and other proceedings. We note, however, that the Due Process Clause of the Fourteenth Amendment to the United States Constitution generally is accepted as the source of the various constitutional standard-of-proof requirements recognized by the courts, see, e.g., In re Winship, 397 US 354, 364, 90 S Ct 1068, 25 L Ed 2d 368 (1970) (holding that Due Process Clause requires proof beyond a reasonable doubt in criminal proceeding), and that the Oregon Constitution contains no due process clause or anything comparable to it, State v. Miller, 327 Or 622, 635 n 10, 969 P2d 1006 (1998).
Finally, we conclude that the third identified change — the requirement that the value of forfeited property be substantially proportional to the predicate offense — also is an addition to, and does not affect any existing provision in, the Oregon Constitution. We reject plaintiffs’ suggestion that the change affects Article I, section 16, which provides that “all penalties shall be proportional to the offense.” Article I, section 16, applies only in criminal proceedings, Oberg v. Honda Motor Co., 316 Or 263, 274-75, 850 P2d 371 (1993), rev’d and rent’d on different grounds, Honda Motor Co v. Oberg, 512 US 415, 114 S Ct 2331, 129 L Ed 2d 336 (1994), *510while the proportionality requirement at issue speaks to a civil proceeding.
Having determined that the three identified changes do not alter or affect different provisions of the existing constitution, we may proceed to consider whether the three changes are themselves closely related. We think that it is clear that the changes are all parts of an effort to define the judicial process for forfeiture in constitutional terms. The first part of subsection (3) describes that judicial process as requiring a predicate conviction to justify commencing the process. The second part sets out the permissible standard of proof in that process. Finally, the third part of subsection (3) provides that the forfeiture process may proceed only to the extent that the forfeiture is proportional to the underlying criminal conviction. Seen in that way, the close, interconnected relationship between the three parts is clear.
Plaintiffs also point to subsection (7) of Measure 3. They contend (and, again, we assume for the sake of argument) that that subsection contains two separate substantive changes to the Oregon Constitution: (1) it prohibits using forfeited property and proceeds for “law enforcement purposes”; and (2) it establishes a priority for distributing forfeited property or proceeds. Plaintiffs recognize that neither part has any analog in the Oregon Constitution and, thus, that neither changes any existing provision of the constitution. As before, then, we need not consider whether existing provisions affected by those changes are closely related to one another: We may proceed to the question of whether the changes identified in subsection (7) are themselves closely related.
We conclude that the two changes are closely related, if they are separate at all. A brief illustration suffices, in that regard: If one looks at the two parts of subsection (7) in reverse order, one first considers the subsection’s direction that forfeiture proceeds be distributed to “the State or any of its political subdivisions to be used exclusively for drug treatment” and then its prohibition on the use of proceeds for “law enforcement purposes.” Viewed from that perspective, the latter provision may be seen for what it is — a limitation on what otherwise would be considered a proper *511distribution of forfeited money “to the State or any of its political subdivisions to be used exclusively for drug treatment, unless another disposition is specially provided by law.” See Meyer, 341 Or at 301 (explaining similar relationship). So understood, the two concepts are not separate at all; one merely delimits the other. At the very least, they are “closely related.”
Finally, we turn to consider whether the changes effected by subsection (3) and the changes effected by subsection (7) are also “closely related to each other” (as before, our determination that those changes do not affect any existing provisions of the Oregon Constitution obviates any need to consider the relationship between existing provisions). Plaintiffs contend that they are not, arguing as follows: Subsection (3) provides increased procedural and substantive protections for property owners to ensure against premature, inaccurate, or excessive forfeitures. Subsection (7), on the other hand, prohibits the executive and legislative branches from using the proceeds of forfeitures for law enforcement purposes and directs how forfeiture revenues shall be used. Plaintiffs argue that the right of property owners to require the state to prove its case by clear and convincing evidence is no more closely related to the prohibition against using forfeiture proceeds for law enforcement purposes than the right of all people to be free from unreasonable searches and seizures, at issue in Armatta, was closely related to the right of the criminally accused to have a unanimous jury. It follows, plaintiffs reason, that, as the court held in Armatta, the changes contained in subsections (3) and (7) of Measure 3 are not closely related and, accordingly, constitute two or more amendments under Article XVII, section 1.
Again, we are unpersuaded. Indeed, it seems to us that plaintiffs’ analysis works only if one stands as close as possible to each provision and ignores the others. To us, it is perfectly clear that the administrative detail provided in subsection (7) is closely related to the substantive changes made in subsection (3): Not only do the people wish to be assured that forfeitures are reined in, they shall encourage it by removing the carrot, which otherwise would tempt the two political branches of government to treat the criminal law as a revenue-raising source. The measure’s sponsors included a *512wealth of detail in the measure, perhaps suspecting darkly that, unless they did, the legislature and the executive somehow would attempt to avoid their policy concern. But we need not agree with that idea, which appears to have motivated the measure’s sponsors, in order to resolve plaintiffs’ claims.
Although the foregoing discussion of subsections (3) and (7) disposes of the subsections at the heart of the disagreement between the parties, we add a further and more general set of observations. Although it has several provisions, Measure 3 itself can be viewed essentially as containing two parts: the first part, encompassing subsections (3) through (6), sets out constitutional protections for property owners by creating a constitutional concept of civil forfeiture proceedings and by imposing a number of procedural protections (and accompanying limitations) in such proceedings; the second part, encompassing subsections (7) through (11), sets out an administrative process for collecting and disbursing funds derived from forfeited property. Both parts add new provisions to the Oregon Constitution; neither changes existing rights or other constitutional provisions. And, as we will discuss, the two parts reasonably can be characterized as containing various provisions that are closely related to each other under the reasoning set out m. Armatta.
Turning to the “closely related” question, it is undeniable that a relationship exists between the two parts: The administrative funding and disbursal scheme (the second change just identified) has a place in the constitution because of the new civil forfeiture process (the first change), and it concerns the disbursal of funds derived from that process. In our view, that relationship is a stronger one than the relationships (or lack thereof) between the constitutional changes at issue in Swett and Armatta. See Swett, 333 Or at 608-09 (although changes purportedly shared same subject matter of limiting influence of money in elections, change that imposed contribution disclosure requirement was not closely related to change that imposed eligibility requirement on initiative signature-gatherers); Armatta, 327 Or at 283-84 (although disparate changes, including right to unanimous jury verdict in murder trials, search-and-seizure protections, right to bail, and juror qualifications were related in sense that they pertained to rights implicated during criminal *513investigation or prosecution, that relationship was insufficient to render them closely related for separate-vote purposes).
From the foregoing, we think that it also is permissible to conclude that the relationship between the two parts of Measure 3 just discussed is sufficiently “close” to pass muster under Article XVII, section 1. That is, the administrative scheme set out principally in subsections (7) to (11) of Measure 3 bears a close relationship to the civil forfeiture proceeding provisions set out in subsections (3) to (6), because it would have no reason for existence were it not for those provisions. The former (i.e., the administrative scheme and money flowing into and out of it) wholly derives from the latter (i.e., the forfeiture proceeding provisions) and from no other source.
For the reasons stated, we hold that Measure 3 does not contravene the “separate-vote” requirement of Article XVII, section 1. The contrary holding of the Court of Appeals was error. It must be reversed.6
The decision of the Court of Appeals is reversed. The judgment of the trial court is affirmed.
Article XVII, section 1, of the Oregon Constitution provides:
“When two or more amendments shall be submitted * * * to the voters of this state at the same election, they shall be so submitted that each amendment shall be voted on separately.”
And, that provision notwithstanding, we shall continue to refer to the measure as “Measure 3” throughout this opinion.
Article IV, section l(2)(d), of the Oregon Constitution provides, in part:
“* * * A proposed * * * amendment to the Constitution shall embrace one subject only and matters properly connected therewith.”
Various organizations and individuals also intervened as plaintiffs. Because their arguments essentially track plaintiffs’ arguments, we do not refer to those interveners separately.
Before Armatta, this court had applied the separate-vote requirement without considering either the wording of the requirement or its history. See Baum, 200 *505Or at 580-81 (stating, without explanation, that a 1952 constitutional amendment “did not submit ‘two or more amendments’ to the voters” in violation of Article XVII, section 1).
As noted, plaintiffs also advanced the notion in the Court of Appeals that Measure 3 violated the “single-subject” limitation found in Article IV, section l(2)(d), of the Oregon Constitution. However, section l(2)(d), which applies to statutory enactments as well as constitutional amendments, is less demanding than the separate-vote requirement of Article XVII, section 1. See Armatta, 327 Or at 276 (so stating). In fact, a constitutional amendment that passes muster under Article XVII, section 1, almost by definition will pass muster under Article IV, section l(2)(d). See id. at 277 (stating that separate-vote requirement encompasses notion that a single constitutional amendment must contain a single subject). We therefore hold that plaintiffs’ arguments under Article IV, section l(2)(d), also are not well taken. It follows that the case need not be remanded to the Court of Appeals for further proceedings. Instead, we can affirm the judgment of the trial court by this opinion.