(dissenting). Justice Connor T. Hansen, dissenting in the Kleczka case, objected to a governor writing laws with the eraser end of the pencil.1 Today the majority allows a governor to write laws with the pointed end of the pencil. I dissent.
The majority holds that a governor has a "write-in" veto power that "extends only to monetary figures and is not applicable ... [to] any other aspect of an appropriation." Majority op. at 511. This holding differentiates between a governor's veto power over appropriation figures and over non-appropriation parts of an appropriation bill, thus contravening the *512language of art. V, sec. 10(l)(b), Wis. Const.,2 and 60 years of case law interpreting that provision.
I do not join the majority opinion because it fails to justify its abandonment of the long-standing interpretation of art. V, sec. 10(l)(b) that, for purposes of the governor's veto power, appropriation amounts are treated the same as words and other numbers in an appropriation bill.
1 — 1
The fundamental rule that the governors veto power extends equally to words, numbers and amounts of appropriations stems directly from the language of art. V. sec. 10(l)(b). The constitution empowers a governor to approve an appropriation bill in whole or in part. The constitution speaks of appropriation bills, not appropriations.
Furthermore, cases dating back 60 years state and restate the principle that a governor's veto power applies to parts of an appropriation bill not dealing with appropriations.3 In State ex rel. Wisconsin Tel. Co. v. Henry, the court for the first time acknowledged that a governor's partial veto power extends equally to words, dollar figures and other numbers contained in an appropriation bill. Henry, 218 Wis. 302, 260 N.W. 486, 489 (1935). See majority op. at 494-95. Since *513Henry, the court often has reaffirmed this axiom.4 The majority opinion implicitly overrules the line of cases adhering to this basic principle that has been followed without deviation for the last 60 years.
This long-standing line of cases interpreting the governor's constitutional veto power should not be abandoned without strong justification to insure that the court is not acting in an arbitrary or capricious manner. Fidelity to precedent, the doctrine of stare decisis, is fundamental to "a society governed by the rule of law."5 When constitutional interpretation is open to revision in every case, "deciding cases becomes a mere exercise of judicial will, with arbitrary, and unpredictable results."6
*514hH l-H
The effect of the majority's effort to distinguish between appropriation figures and other parts of an appropriation bill is easily illustrated.7 The majority allows a governor to delete a monetary appropriation figure and write in a lesser figure as follows:
IjSZGT authorize expenditures not exceeding $2-,000
The majority also permits a governor to write in a word for a monetary appropriation when the legislature has expressed the appropriation in words:
•five ten dollars of each fee to be credited to an appropriation
But, the majority will not allow a governor to write in a new number for the following monetary figure:
I4} 3©o eligible participants shall earn no more than $20,000
Nor will the majority permit a governor to exercise this write-in veto:
bovi v\e all moneys received for animal health testing
The majority gives four reasons to support its unprecedented distinction between the power of a gov-*515emor to veto appropriation figures and to veto all other parts of an appropriation bill.
A.
The majority states that the single issue presented for review is a limited one, requiring only the resolution of a governor's power to strike a numerical sum appropriated and to write in a smaller number. Majority op. at 489, 505. Yet, the majority decides an issue it asserts is not "a valid concern" for this court. Majority op. at 505. It holds that the write-in power "extends only to monetary figures and is not applicable in the context of any other aspect of an appropriation."8 Majority op. at 511 (emphasis added). The majority stresses that "a governor may only reduce an appropriation by a number contained within the original appropriation allotment." Majority op. at 510 (emphasis added). The majority explicitly determines that a governor cannot use a write-in veto to reduce any part of an appropriation bill that is not an appropriation figure. See also majority op. at 511-12, n.18, reiterating its holding that a governor's write-in power does not apply to nonappropriation parts of an appropriation bill.
The majority goes further and concludes that a governor can strike an appropriation sum set forth in words. The majority explains that if the legislature "chooses to write out the amount of the appropriation in word form" a governor can reduce the sum with a *516write-in veto because "the underlying conceptual framework is the same — a 'part' of a larger appropriation sum is any sum, whether written out in words or specified with numerals." Majority op. at 507, n.13.9
The majority opinion is thus a series of contradictions, summarized as follows: (1) The majority says the only issue before the court is whether a governor may write in a lesser appropriation figure. (2) Nevertheless the majority decides that a governor may not write in a lesser number of a nonappropriation figure, or a lesser concept encompassed in words. (3) Then the majority decides that if an appropriation sum is expressed in words, a governor may write in words representing a lesser appropriation sum because the underlying conceptual framework is what matters.
B.
The majority relies almost exclusively on the Wisconsin Senate case to support its distinction between appropriation figures and nonappropriation parts of an appropriation bill. The majority claims that Wisconsin Senate "for the first time . . . set forth a dichotomy between a governor's partial veto power over appropriation figures and over nonappropriation parts of an appropriation bill. . .." Majority op. at 500. Wisconsin Senate, it claims, upholds a governor's power to "reduce an appropriation, whereas he may only strike out letters, digits or words" of nonappropriation parts. Majority op. at 500 (emphasis added).
The majority's claim perches precariously on the following language in Wisconsin Senate: "We conclude, *517consistent with the broad constitutional power we have recognized the governor possesses with respect to vetoing single letters, words and parts of words in an appropriation bill, that the governor has similar broad powers to reduce or eliminate numbers and amounts of appropriations . . Majority op. at 499 (quoting Wisconsin Senate, 144 Wis. 2d at 457) (emphasis added).
Reliance on this language is mistaken for at least five reasons.
1. Even a cursory reading of this language in Wisconsin Senate demonstrates that the court parcels a governor's partial veto power into three categories: (1) to veto words by striking single letters, words or parts of words, (2) to reduce or eliminate numbers, and (3) to reduce or eliminate amounts of appropriations. The majority misconstrues the second category by refusing to acknowledge that a governor can reduce numbers that are not appropriation figures. Instead, the majority merges the first and second categories (all words and nonappropriation numbers) as parts that a governor may "strike" while suggesting that a governor has the power to "reduce" with a write-in veto only appropriation figures. Majority op. at 511. Wisconsin Senate, however, expressly allows a governor to "reduce or eliminate numbers," as well as to "reduce or eliminate amounts of appropriation" in an appropriation bill. The Wisconsin Senate court in fact upheld the governor's striking of digits to reduce the amount an air pollution producer must pay from "$2,000" to "$200."10
*5182. If Wisconsin Senate makes for the first time the distinction the majority claims, that case departs from precedent. Assuming the majority is correct in reading Wisconsin Senate as announcing a new rule, Wisconsin Senate offers no rationale for abandoning precedent and creating a dichotomy between the governor's power to veto appropriation figures and the power to veto all other parts of an appropriation bill. Wisconsin Senate provides no explanation for its supposed conclusion that only appropriation figures may be "reduced" while all other parts may be "stricken." The 33 page opinion in Wisconsin Senate, authored by Chief Justice Nathan S. Heffeman, is silent on this issue.
3. Wisconsin Senate unambiguously determined that a governor's veto power is "similar" with respect to all three categories. The Wisconsin Senate court made no distinction between a governor's power to veto words, to strike letters, to reduce or eliminate numbers, and to reduce or eliminate appropriation amounts. Wisconsin Senate considered words, letters, numbers and appropriation amounts together, stating that "the governor has the authority to veto sections, subsections, paragraphs, sentences, words, parts of words, letters, and digits included in an appropriation bill . . .." Wisconsin Senate, 144 Wis. 2d at 462. The court not only refused to differentiate between words and digits, but also refused to distinguish among digits reflecting appropriation figures, digits reflecting other *519monetary sums and digits reflecting nonmonetary numerical concepts.
4. In Wisconsin Senate the only issue was a governor's power to strike parts of an appropriation bill. All of the 37 partial vetoes at issue in Wisconsin Senate were effected by striking letters, words, numbers or appropriation sums. The court concluded that "the governor may, in the exercise of his partial veto authority over appropriation bills, veto individual words ... and digits, and may also reduce appropriations by striking digits." Wisconsin Senate, 144 Wis. 2d at 437 (emphasis added). See also Wisconsin Senate, 144 Wis. 2d at 458. Thus, Wisconsin Senate's use of the verb "reduce" to describe a partial veto of numbers and appropriation amounts merely recognizes that a governor can invoke the partial veto power to decrease numbers and appropriation amounts by striking digits.11 The opinion in Wisconsin Senate frequently equates the power to strike with the power to reduce.
5. Wisconsin Senate explicitly refused to consider the constitutionality of a write-in veto power. The court expressly stated that "we do not decide the issue of whether the governor may reduce appropriations by writing in a different and smaller number than that *520passed by the legislature . . Wisconsin Senate, 144 Wis. 2d at 460, n.17.
The majority errs in its attempt to read Wisconsin Senate as an oracle foretelling of a write-in veto power for appropriation figures. Wisconsin Senate concluded that it did not "break ... new ground." Wisconsin Senate, 144 Wis. 2d at 437. The court expressly stated that "this case makes no new law." Wisconsin Senate, 144 Wis. 2d at 463.
C.
The majority justifies the write-in veto power for only appropriation figures by concluding that $250,000 is "part" of $350,000. It does so by relying on the definition of the word "part" set forth in Henry, 218 Wis. at 313. Majority op. at 506-07. That definition, as the majority opinion recognizes, confers on the word "part" its ordinary and accepted meaning. Henry teaches that the word "part" includes "a number, quantity, mass, or the like, regarded as going to make up, with others or another, a larger number, quantity, mass, etc." Henry, 218 Wis. at 313. The majority fails to explain how this broad definition justifies a write-in of a lesser appropriation figure but prohibits both a write-in of a lesser number not part of an appropriation figure and a write-in of a lesser concept encompassed in a word (unless that word is an appropriation sum). The majority merely concludes that a" 'common sense' reading of the word part, in terms of appropriation amounts, is what is intended in sec. 10(l)(b)." Majority op. at 507 (emphasis added).
There is no " 'common sense' reading of the word part" that supports the majority in limiting a governor's veto power to striking out parts that are made up of certain words and numbers and at the same time *521expanding a governor's veto power to writing in parts that are appropriation amounts (both figures and words). On the . contrary, heeding the broad definition of the word "part," "common sense" would dictate that "if numbers can be written in so can words .... The governor might veto the words, 'State of Wisconsin' and write in 'City of Milwaukee,' because Milwaukee is part of Wisconsin." Petitioners' brief at 5-6.
The most common sense interpretation of the word "part" in art. V, sec. 10, is that it means a physical part of an appropriation bill, so that only the text physically present in a bill can be subject to the governor's partial veto power. The 100,000 by which the Governor reduced the appropriation is a part of the 350,000 appropriation only conceptually; 100,000 and 250,000 are not physically part of the text appropriating the sum of 350,000. This interpretation of "part" fits the definition articulated in Henry and repeated throughout the cases construing a governor's partial veto power. It also comports with the rule that there is no substantive difference between appropriation figures and all other parts of an appropriation bill. Finally, reading the word "part" to include only parts physically included in a bill adheres to the "four corners of the bill rule," instructing that a governor may veto only material physically within the four corners of a bill. State ex rel. Finnegan v. Dammann, 220 Wis. 143, 147-148, 264 N.W. 622 (1936); Wisconsin Senate, 144 Wis. 2d at 456.
D.
The fourth "reason" the majority gives for its distinction between appropriation figures and all other parts of appropriation bills is that both parties to this action "recognize that the governor never has written in a word and does not claim the authority to do so." *522Majority op. at 509. This assertion provides no support for the majority's distinction; it is nothing more than a statement of fact. Prior to 1990 no governor had ever reduced appropriation figures by writing in new digits, yet the majority opinion now validates that practice. Even the governor's "concession" that he does not have the power to write in words does not justify the majority's distinction. A governor's assertion about a correct interpretation of the state constitution is not binding on future governors or on this court.
III.
It is difficult to predict the consequences of the majority's unpersuasive explanations for treating appropriation figures as different from all other parts of an appropriation bill. This decision will either severely limit a governor's partial veto power or broadly expand it.
If in a future veto case the court finds the majority opinion persuasive in its effort to distinguish between appropriation figures and all other parts of an appropriation bill, the court will necessarily conclude that this decision overruled sub silentio our cases determining that no distinction exists between the various parts of an appropriation bill. The court will then be able to write on a clean slate, perhaps allowing a governor to exercise broad partial veto methods over appropriation figures, but limiting partial veto methods over other parts of an appropriation bill.
Under another scenario, a future governor will strike out a word and write in a conceptual part of that word, arguing that the majority's effort to distinguish between appropriation figures and other parts of an appropriation bill was unpersuasive. When the majority's hollow distinction between appropriation figures *523and other parts of an appropriation bill falls, the majority opinion may be used to uphold a governor's writing in words, thus once again extending the partial veto power far beyond its previous scope. A governor could use this write-in veto to create new entities, dates, durations, percentages, distances and more. For example, were the legislature to create a "state" advisory board, a governor could fabricate a "Rusk county" advisory board; a legislative grant to "counties" could become a grant to "cities" or a grant to "people over the age of 45 living in specified counties"; an education project established for "2 years" could be shortened to its component parts such as "8 months" or "30 days"; and a legislatively established marketing program for "vegetables" could be construed as a program for "cabbage."
The only way to avoid wreaking havoc on the scope of a governor's partial veto power, to keep from abandoning long-standing interpretation of art. V, sec. 10(l)(b), and to avert the inconsistencies inherent in the majority opinion is to declare the governor's write-in veto unconstitutional. Accordingly, I conclude that Governor Thompson's write-in veto exceeded the constitutional powers granted to a governor by art. V, sec. 10, because the "part objected to" was not physically part of the text of an appropriation bill. I base this interpretation of the constitution on the text of the constitution and our prior cases which impart four teachings relevant to resolving the issue presented in the instant case.
First, the court has set forth a "four corners of the bill" rule to define the material a governor may partially veto, Wisconsin Senate, 144 Wis. 2d at 456,12 and *524to determine whether a bill is an appropriations bill, Finnegan, 220 Wis. at 147-148.13
Second, the court has declared that the constitutionality of a partial veto does not depend on the substantive content of the part vetoed. A partial veto can be used to change not only an appropriation but any part of an appropriation bill. Kleczka, 82 Wis. 2d at 708; Sundby, 71 Wis. 2d at 130.
Third, the court has on numerous occasions stated that "what the legislature has assembled, the governor can disassemble 'part' by 'part.'" Wisconsin Senate, 144 Wis. 2d at 441. See also Kleczka, 82 Wis. 2d at 706; Sundby, 71 Wis. 2d at 131-32; Henry, 218 Wis. at 315. A coextensive partial veto power means that a governor disassembling a bill is limited to the same building blocks the legislature used to assemble the bill, not that the governor may add new blocks.14 The gover*525nor's coextensive power with the legislature is merely the power to excise physical parts of the bill, not add new language.
Fourth, the court has given great weight to the established practices of the executive and legislative branches in evaluating the scope of the partial veto power. Wisconsin Senate, 144 Wis. 2d at 452-53; Kleczka, 82 Wis. 2d at 703. Apparently, prior to 1990, no governor attempted to write anything into an appropriation bill. The method for a governor’s "disassembling an appropriation bill" has been by deleting phrases, words, parts of words, letters, digits or punctuation from a bill. No governor has previously written in phrases, words, parts of words, letters, digits or punctuation.15
I conclude that the constitution forbids expanding the partial veto methods to include a write-in power. For the reasons set forth, I dissent.
I am authorized to state that Chief Justice NATHAN S. Heffernan and Justice William A. Bablitch join this dissent.
State ex rel. Kleczka v. Conta, 82 Wis. 2d 679, 720, 264 N.W.2d 539 (1978) (Connor T. Hansen, J. dissenting).
Article V, sec. 10(l)(b) of the Wisconsin Constitution provides:
If the governor approves and signs the bill, the bill shall become law. Appropriation bills may be approved in whole or in part by the governor and the part approved shall become law.
State ex rel. Sundby v. Adamany, 71 Wis. 2d 118, 131, 237 N.W.2d 539 (1978).
See State ex rel. Martin v. Zimmerman, 233 Wis. 442, 289 N.W. 662 (1940) (relying on Henry to uphold a partial veto that changed not just monetary figures but altered the legislative policy); State ex rel. Sundby v. Adamany, 71 Wis. 2d 118, 129, 237 N.W.2d 910 (1976) (summarizing the lessons from prior cases to be that "the chief executive of this state [is] empowered by the constitutional provision to veto all parts of an appropriation bill regardless of their nature ....); State ex. rel. Kleczka v. Conta, 82 Wis. 2d 679, 264 N.W.2d (1978) (upholding the governor's power to strike from an appropriation bill not only appropriation figures but words and phrases as well); State ex rel. the Wisconsin Senate v. Thompson, 144 Wis. 2d 429, 437, 424 N.W.2d 385 (1988) (concluding that "the governor may, in the exercise of his partial veto authority over appropriation bills, veto individual words ... and digits, and also may reduce appropriations by striking digits —").
Akron v. Akron Center for Reproductive Health, Inc., 462 U.S. 416, 420 (1983).
Appeal of Concerned Corporators of Portsmouth Savings Bank, 129 N.H. 183, 227, 525 A.2d 671 (1987) (Souter, J. dissenting, quoting Thornburg v. College of Obstetricians and *514Gynecologists, 476 U.S. 747, 786-87 (1986) (White, J. dissenting)).
These examples are based on actual language in 1993 Senate Bill 44, the appropriation bill in which the governor executed the write-in veto at issue. See secs. 88zg, 130h, 159, and 254.
Because the most common definition of "figure" is "a number symbol; numeral, digit.,Webster's Ninth New Collegiate Dictionary (1990), one would assume that the majority would not permit a governor to change an appropriation amount written in words rather than numbers. This assumption is incorrect. See majority op. at 507, n.13.
The legislature's use of words, rather than numbers, to state an appropriation sum is not unusual. See the illustration from the 1993 Senate Bill 44 set forth above at p. 515.
See Petitioner's Appendix to Brief in Wisconsin Senate at 129,139.
Wisconsin Senate also upheld the governor's veto of part of a provision creating a council of "9 members, of whom 5 shall be *518appointed by the governor." The result of this veto was a council of "9 members who shall be appointed by the governor."
The court has also stated that the way to restrict a governor's partial veto authority to items of appropriation is for the legislature to submit appropriation bills containing only appropriations. Wisconsin Senate, 144 Wis. 2d at 455.
In addition to the words "reduce," "strike," and "veto," the court has used a number of verbs to describe what a governor does by exercising the partial veto power: "Acting Governor Schreiber exercised his partial veto by lining out the words ..." Kleczka, 82 Wis. 2d at 685; ”[a]s changed by the Governor's partial veto_", Id.; "the question remains whether the words excised were appropriately removed," Id. at 703; "[t]he governor disapproved certain portions [of the bill]", Sundby 71 Wis. 2d at 122; "in the exercise of the item veto the governor can negative what the legislature has done —", Id. at 134.
In upholding the governor's veto of "repealed and recre= ated," Wisconsin Senate explained that "the legislature chose to *524repeal and recreate [a statute] within the four comers of the omnibus budget bill. That legislative enactment — even though it was not itself an appropriation — therefore, became subject to the governor's partial veto authority." Wisconsin Senate, 144 Wis. 2d at 456. Thus, because the words were within the four comers of the appropriation bill, the governor could veto them.
The court concluded that the legislation was not an appropriation bill because there was no appropriation within the four corners of the bill. The partial veto power, the court reasoned, is broad but should not be interpreted to extend beyond the text of the bill at issue.
The Henry decision first gave voice to the concept of a coextensive veto power by linking the concept of a partial veto with the "legislature's power to join and enact separable pieces of legislation in an appropriation bill." Henry, 218 Wis. at 315. The Henry language, properly understood, means that a governor's power is coextensive with the legislature's in the sense that a governor has "the right to pass independently on every separable piece of legislation in an appropriation bill," and to *525either approve or veto each part that the legislature has physically included. Henry, 218 Wis. at 315.
Legislative Reference Bureau, The Partial Veto in Wisconsin — An Update, Information Bulletin, 87-IB-3 (Rev. Aug. 1988).