with whom Saitta, J., agrees, dissenting:
I am deeply troubled by the majority’s decision in this case to strike a candidate from the ballot while ignoring important constitutional and statutory challenges raised by the candidate. I would reach those issues, reverse the district court’s decision, and direct that Candelaria appear on the ballot as a candidate for justice of the peace. In light of these circumstances, I dissent.
Single-subject requirement
This appeal presents the perfect opportunity for this court to reconcile the different approaches it has taken in applying Nevada’s constitutional and statutory single-subject requirements. Nev. Const, art. 4, § 17; NRS 295.009. Article 4, Section 17 requires that “[ejach law enacted by the Legislature shall embrace but one subject, and matter, properly connected therewith, which subject shall be briefly expressed in the title.” Under NRS 295.009(l)(a), voter initiatives or referenda must “[ejmbrace but one subject and matters necessarily connected therewith and pertaining thereto.” In my view, these requirements are the same, but this court treats them differently.
This court’s approach to Article 4, Section 17 single-subject challenges is embodied in Wise v. Bechtel Corp., 104 Nev. 750, 754, 766 P.2d 1317, 1319 (1988). In Wise, this court announced that “[t]he main test of the application of [Article 4, Section 17] to a particular statute is whether the title is of such a character as to mislead the public and the members of the legislature as to the subjects embraced in the act ... .” Id. at 754, 766 P.2d at 1319 (internal quotation omitted). In reaching its conclusion, the Wise court stated that it “liberally construed the one subject [rule] and briefly expressed clauses of Article 4, § 17.” Id. at 754, 766 P.2d at 1319 (citing State v. Payne, 53 Nev. 193, 197, 295 P. 770, 771-72 (1931) (stating that “[t]he constitutional requirement, though mandatory, must be liberally construed, lest meritorious legislation be declared void by reason of inartificiality in the title”)).
This liberal application stems from our prior precedent, wherein we summarily disposed of Article 4, Section 17 challenges. See Westinghouse Beverage v. Dep’t Taxation, 101 Nev. 184, 190, 698 P.2d 866, 869 (1985) (summarily rejecting, without explanation, an Article 4, Section 17 challenge to a tax on importing for sale at retail or selling at wholesale soft drinks or syrups and powders used to make soft drinks); McLaughlin v. L.V.H.A., 68 Nev. 84, 97-98, 227 P.2d 206, 212-13 (1951) (dismissing, without explanation, an Article 4, Section 17 challenge to housing authority laws); Ex Parte Cerfoglio, 44 Nev. 343, 347-48, 195 P. 96, 97 (1921) (declaring, without explanation, that Article 4, Section 17, “though mandatory, should be liberally construed”). But this was not always the court’s approach. In State v. Commissioners of *419Humboldt County, 21 Nev. 235, 237, 29 P. 974, 975 (1892), this court noted that one objective behind Article 4, Section 17 was “to prevent the uniting in one act of several independent and disconnected matters, good, bad and indifferent, many of which could not be carried upon their own merits, but by uniting them together in . . . each measure, enough strength could be mustered to push it through.’ ’
Nevertheless, this court’s focus has consistently been on the title of a legislative act and making sure that the title encapsulates the substance of a bill rather than focusing on whether the bill addresses multiple subjects. Sheriff v. Miller, 93 Nev. 509, 510-11, 569 P.2d 401, 402 (1977) (disposing of an Article 4, Section 17 challenge by concluding that a statute’s content was “logically germane to the subjects expressed in the title”); State ex rel. Brennan v. Bowman, 89 Nev. 330, 333-34, 512 P.2d 1321, 1323 (1973) (restricting the Article 4, Section 17 review to the statute’s title); McCormick v. District Court, 69 Nev. 214, 221, 246 P.2d 805, 808-09 (1952) (same). But by focusing only on the title, the court has eviscerated the remainder of Section 17, which clearly and unambiguously mandates that each law enacted by the Legislature encompass only one subject.
Unlike the Wise approach, voter initiatives and referenda will only survive a single-subject challenge “if the parts of the proposed initiative or referendum are functionally related and germane to each other in a way that provides sufficient notice of the general subject of, and of the interests likely to be affected by, the proposed initiative or referendum.” NRS 295.009(2); see also Las Vegas Taxpayer Comm. v. City Council, 125 Nev. 165, 176-80, 208 P.3d 429, 436-39 (2009) (determining that NRS 295.009 applies to municipal ballot measures and concluding that the proposed initiative was invalid on statutory single-subject grounds); Nevadans for Prop. Rights v. Sec’y of State, 122 Nev. 894, 901-09, 141 P.3d 1235, 1240-45, (2006) (rejecting constitutional challenges to NRS 295.009 and concluding that the proposed initiative violated the statutory single-subject requirement). This court’s different treatment given to acts of the Legislature and voter-sponsored initiatives and referenda creates an untenable situation. As a result, voter-sponsored initiatives and referenda are treated as less important than legislative acts, which are afforded more deference by this court. Given the similarity of language and purpose behind the two single-subject provisions, the application of vastly different requirements in determining compliance with the provisions is wholly improper. See State ex rel. Caleb v. Beesley, 949 P.2d 724, 728 (Or. 1997) (determining that there was no meaningful textual difference between the single-subject requirements afforded legislatively enacted laws and initiative petitions by the Oregon state constitution and that precedent from both constitu*420tional provisions were relevant in determining whether an enacted ballot measure was unconstitutional under the Oregon constitution).
And while Article 4, Section 17 lacks the clear definition of the appropriate method of review, as provided in NRS 295.009(2), that statute’s “functionally related and germane” requirement is largely identical to this court’s seemingly abandoned statement in Humboldt that Article 4, Section 17 requires that bills not address “several independent and disconnected matters.” 21 Nev. at 237, 29 R at 975.1 would resurrect and give force to the Humboldt language to ensure that bills enacted by the Legislature are subject to similar requirements as those applicable to voter initiatives and referenda. Applying this approach to the case at hand, I would strike down the 2005 amendments to NRS 4.010 as violating this constitutional provision.
NRS 4.010(2) (a) is ambiguous
The majority’s conclusion that NRS 4.010(2)(a)’s language is clear and unambiguous confounds me. Nothing in the statute sets forth any manner for determining when an attorney has complied with the five-year requirement. As a result, the majority develops its own way for making this determination. The majority’s interpretation of the statute’s language is reasonable, but Candelaria offers an equally reasonable interpretation of the statute. As Candelaria points out, the record demonstrates that the State Bar has assessed her membership fees at the rate applicable to “[a]ctive members admitted to practice in any jurisdiction 5 years or more.’ ’ SCR 98(9). Because the State Bar is an arm of this court, it can reasonably be said that, in the eyes of this court, which is vested with the inherent power to define the practice of the law in this state, In re Lerner, 124 Nev. 1232, 1237, 197 P.3d 1067, 1071 (2008), Candelaria has been deemed a fifth-year attorney under language that is fundamentally identical to that used in NRS 4.010(2)(a).1
In light of these competing reasonable interpretations of NRS 4.010(2)(a), the statute simply cannot be classified as unambiguous. I find it interesting that this court has not hesitated to find ambiguity in statutes and constitutional provisions establishing other time periods, see Nevada Mining Ass’n v. Erdoes, 117 Nev. 531, 26 P.3d 753 (2001) (interpreting the phrase “not later than mid*421night Pacific standard time” to permit the Legislature to act until 1 a.m.); SNEA v. Lau, 110 Nev. 715, 718, 877 P.2d 531, 534 (1994) (determining that the term “years,” as used in Article 5, Section 3 of the Nevada Constitution was ambiguous), and I struggle to see the justification for failing to reach a similar result in this case.
This court’s precedent mandates that we interpret any ambiguity in favor of a challenged candidate’s eligibility to run for public office. SNEA, 110 Nev. at 720, 877 P.2d at 535. And we have held that a litigant seeking to challenge a candidate’s eligibility for the ballot “should prevail only if the [provision providing the candidate restriction] cannot possibly refer to anything- other than” a single reasonable interpretation. Id. Thus, because I conclude that NRS 4.010(2)(a) is ambiguous, the statute must be interpreted in favor of permitting Candelaria to appear on the ballot and allowing the voters to make the final decision on this matter. Id.
Equal protection rights
Finally, in rejecting Candelaria’s equal protection contention, the majority glosses over the immense disparity of required qualifications created by NRS 4.010(2)(a) for urban and rural justices of the peace. In most urban areas, a candidate for justice of the peace must be an attorney, licensed and admitted to practice law for not less than five years, while elsewhere, a candidate need only have a high school diploma or “its equivalent.” NRS 4.010(2). However, NRS 4.010(2)(a) and (b) do not distinguish between all urban and rural communities. Although NRS 4.010(2)(a) requires justices of the peace to be attorneys with five years of experience in Clark County for townships with populations above 100,000, NRS 4.010(2)(b) only requires justices of the peace to be attorneys with five years of experience in Washoe County for townships with populations above 250,000. Therefore, a justice of the peace in the urban area of Sparks Township does not have to be an attorney. What is the rational basis for this township population disparity between Clark and Washoe counties? In addition, it has long been common practice in Clark County for justices of the peace from small townships, who are not attorneys, to sit and hear court calendars in Nevada’s largest township, Las Vegas Justice Court. When comparing and considering these different requirements, Candelaria’s equal protection arguments become far more compelling and demonstrate that a violation of her equal protection rights has occurred.
Further, under the scheme created by NRS 4.010(2)(a), in this state’s capital, Carson City, a person with business before the justice court could have his or her case decided by a justice of the peace with only a high school diploma or “its equivalent.” In stark contrast, a litigant with the same business in Las Vegas or Reno *422justice courts could not have his or her case heard by an individual who graduated from one of this country’s most prestigious colleges, attended one of the nation’s most highly regarded law schools, and worked as an associate at a major law firm or as a staff attorney for this court for four years, as that person would not have the required five years of experience.2 This situation is shameful and cannot possibly further any legitimate interests of this state.
I would further note that we recently concluded that the censure of an elected public officer by the Nevada Commission on Ethics for alleged voting infractions violated the First Amendment. See Corrigan v. Commission on Ethics, 126 Nev. 277, 236 P.3d 616 (2010). In Corrigan, we cited Citizens United v. Federal Election Commission, 558 U.S. 310 (2010), for the proposition that NRS 281A.420(2)(c) must be declared unconstitutional because the statute was not narrowly tailored to meet a compelling government interest. We reviewed this statute under a strict scrutiny analysis.
As we acknowledged in Nevada Judges Ass’n v. Lau, “‘[t]he right to hold public office is one of the valuable rights of citizenship. The exercise of this right should not be declared prohibited or curtailed except by plain provisions of the law. Ambiguities are to be resolved in favor of eligibility to office.’” 112 Nev. 51, 55, 910 P.2d 898, 901 (1996) (quoting Gilbert v. Breithaupt, 60 Nev. 162, 165, 104 P.2d 183, 184 (1940)). Therefore, NRS 4.010(2) must be reviewed under a strict scrutiny analysis. Thus, I would strike down NRS 4.010(2)(a) as violating Candelaria’s equal protection rights3 by creating an absurd distinction that cannot withstand even the lowest level of judicial scrutiny.
Compare SCR 98(9) (designating, among other categories, “[a]ctive members admitted to practice in any jurisdiction 5 years or more” as subject to a certain dues rate) with NRS 4.010(2)(a) (requiring certain justice of the peace candidates to be “an attorney . . . licensed and admitted to practice law in the courts of this State ... for not less than 5 years at any time preceding his or her election or appointment”).
One notable exception to NRS 4.010(2)(a)’s heightened qualifications for urban justices of the peace is the fact that, under NRS 4.010(3), these requirements do not apply to individuals already serving as justices of the peace prior to June 30, 2001. This exception deals a fatal blow to any argument that these heightened requirements are necessary to protect the justice courts’ ability to conduct business in more populous areas. If these additional requirements were truly vital, the Legislature would have necessarily barred all individuals who failed to meet those requirements from serving as justices of the peace, regardless of whether they already held the office.
While I acknowledge that, in Goodson v. State, 115 Nev. 443, 991 P.2d 472 (1999), this court concluded that permitting nonlawyers to preside over criminal trials punishable by jail sentences in rural areas does not violate the defendant’s equal protection or due process rights, I question the continuing viability of this decision in light of the significant population growth experienced by this state prior to the current economic downturn.