Alaskans for Efficient Government, Inc. v. State

EASTAUGH, Justice,

with whom CARPENETI, Justice, joins, dissenting.

I would affirm. Applying the appropriate deferential standard of review to the language of the ballot summary and considering the appellants' arguments, I think that the language of the ballot summary satisfies article XI, section 8 of the Alaska Constitution, AS 15.45.090, and AS 15.45.180, and that the changes this court proposes are, at most, unnecessary improvements.

Our review is deferential1 Our deference should derive in part from the expertise inherent in developing language that adequately summarizes ballot propositions and that voters can easily understand. The responsibility for developing that language is vested by constitution and statute in the Heutenant governor.2 We should assume that the executive branch by exercising that responsibility has developed some institutional skill in preparing summaries. In comparison, the judicial branch only infrequently reviews these summaries3 Alaska Statute 15.60.005 *738strongly implies that technical expertise is involved in crafting summaries. That statute specifies a readability test for certain election materials,4 including this ballot summary, and precludes the courts from enjoining the conduct or results of an election for a failure to satisfy the test.5 The current proposition apparently satisfies this statute. This court does not even attempt to determine whether the summary as modified will satisfy AS 15.60.005, and instead leaves it to the lieutenant governor to apply that statute on remand.6 The expertise the executive branch will bring to that exercise helps confirm why our review should be deferential.

The court's order acknowledges the deferential standard of review,7 but it is hard to square that acknowledgment with the modifications the order proposes. They appear, at best, to be mere improvements, not changes essential to remedy any alleged defects. They certainly do not adopt the intrusive (and unjustified) changes the appellants propose. The subtlety of the court's changes suggests that the court is not being as deferential as it should be.

As to the merits, I agree with the decision of the superior court. The ballot summary focuses on the core effect of the present proposition: it will overturn the fundamental purpose of the FRANK Initiative. That fundamental purpose is codified as AS 44.06.050, and was not merely part of the initiative's legislative history. It guarantees to the people "their right to know and to approve in advance" all costs of relocating the capital or the legislature.8 The current ballot summary approved by the lieutenant governor appropriately described this core right and made it a prominent part of the summary.

The objections raised by Alaskans for Efficient Government, Inc., are unpersuasive. The changes they propose would make the current summary markedly less truthful and less impartial. Their changes would simply ignore the core purpose of the FRANK Initiative, the guarantee of the right of people to know all relocation costs. The resulting inaccuracy and partiality consequently inhering in the language advanced by Alaskans for Efficient Government, Inc., justify rejection of the changes they propose.

The court's order concludes that the summary does not adequately describe the changes the initiative proposes to make and that it casts the initiative's purpose in an unnecessarily negative light.9 The order also concludes that the current summary is not "true and impartial,."10 °

I disagree with these conclusions for several reasons that need little elaboration. First, the summary is essentially true and impartial. Second, it adequately describes the changes the present proposition would make; the current summary certainly does as much now in that regard as it will if it is changed as the court's order proposes. Third, a summary limited to 100 words must necessarily be a summary. It is sufficient if it captures the essential elements of the proposal, and it did so here. Finally, the current summary *739does not cast the proposition in a negative light; the only possible theory that it does so requires us to assume that the word "as" in the last sentence of the summary was intended to make it appear that the proposition would conceal from voters information that already exists generated by a commission that already exists.11 This theory places extraordinary weight on an innocuous little word. The summary correctly described the essence of the proposition's purpose. Although adding the words "would be" will not diminish the current summary's impartiality, doing so will not enhance its impartiality either. -

The current summary is not deficient, nor are the improvements the court's order proposes critical to understanding the present proposition. I would therefore affirm.

. Order at 735. See Burgess v. Alaska Lieutenant Governor, 654 P.2d 273, 276 (Alaska 1982). As the court's order observes, "This means that we will not invalidate the summary simply because we believe a better one could be written; instead, 'the lieutenant governor's summary [will] be upheld unless we [cannot] reasonably conclude that the summary [is] impartial and accurate."" Order at 735.

. Alaska Const. art. XI, § 4 ("'The Heutenant governor shall prepare a ballot title and proposition summarizing the proposed law...."); AS 15.45.180(a) ("[The lMeutenant governor, with the assistance of the attorney general, shall prepare a ballot title and proposition.").

. "We have addressed the adequacy of a lieutenant governor's ballot summary in only one previous case ...." Order at 735.

. AS 15.60.005 states:

Readability of certain election materials.
(a) The policy of the state is to prepare a ballot proposition that is clear, concise, and easily readable. The form of each ballot proposition shall be scored under (c) of this section. The policy of the state is to prepare a ballot proposition that is scored at approximately 60.
(b) Each neutral summary prepared for the voter's pamphlet shall be scored under (c) of this section. The policy of the state is to prepare a neutral summary that is scored at approximately 60.
(c) A ballot proposition or neutral summary shall be scored using the following procedures:
(1) disregard numbers;
(2) multiply the average sentence length in words by 1.015;
(3) multiply the average number of syllables for each 100 words by .846;
(4) subtract the total of (2) and (3) from 206.835.
(d) A court may not enjoin the conduct or results of an election for a failure to comply with (a) or (b) of this section.

. AS 15.45.180 requires a ballot summary to comply with AS 15.60.005.

. Order at 737 n. 19.

. Order at 735.

. AS 44.06.050.

. Order at 736-737.

. Order at 737.

. Thus, the order states that, "When combined with its concrete statement describing the initiative's repeal of the existing law's purpose of revealing the costs of a move to the electorate, the summary's past-tense phrasing-'as determined by a commission -can easily be read to mean that an existing commission has already determined the costs and that the initiative seeks to keep them secret." Order at 736-737. I think the summary cannot "easily be read" to have that meaning.

The sponsors' appellate briefs do not seem to argue that this language is susceptible to the reading the court attributes to it. Perhaps the court's reading derives from appellants' relatively cryptic argument that implies that the sponsors have been unfairly blamed for trying to hide the relocation costs. But the ballot proposition, if it passes, will do away with the need to appoint a public commission charged with determining relocation costs. Given this purpose, it seems incorrect to argue that the summary is inaccurate. And this purpose also seems to be inconsistent with an argument implying that it is unfair to blame the appellants for trying to prevent voters from knowing the costs of a relocation.