In Advisory Opinion to the Attorney General re People's Property Rights Amendments, 699 So. 2d 1304 (Fla. 1997), the Attorney General requested that the Court review three proposed amendments to ensure compliance with applicable law. See 699 So. 2d at 1306. After reviewing all three proposed amendments, we determined that none satisfied the requirements of section 101.161 of the Florida Statutes, and concluded that all three should not appear on the ballot. See id. at 1312. In so holding, the Court noted that the divergence in terminology between the ballot title and summary in one of the amendments would be confusing to the voter. See id. at 1308. Additionally, the Court as concerned that the legal phrases "common law nuisance," "loss in fair market value," and "exemption" were not defined, and that this lack of definition created uncertainty as to the actual effect of the proposed amendments. Id. at 1309, 1312. Moreover, we noted that the language of one of the amendments submitted for review was misleading because its definition of a new tax as "increases in tax rates . . . did not distinguish between an increase in . . . money paid . . . or the actual tax rate. " Id. at 1311. The Court determined that the summary for an initiative involving voter approval for new taxes was misleading. See id. at 1311. The summary at issue read: Requires voter approval of new state, local or other taxes. New taxes include initiation of new taxes, increases in tax rates and eliminating tax exemptions. Allows emergency tax increases, lasting up to 12 months, if approved by three-fourths of a taxing entity's governing body. (Id. at 1309.) The Court deemed the summary's definition of "new tax" as "increases in tax rates" misleading because it did not distinguish between an increase in the amount of money paid on taxable property or the actual rate at which the property is being taxed. See id. at 1311. The Court also determined that the absence of a more complete definition of the term "exemption" was misleading because the voting public would not understand the distinction between exemption and immunity from taxation. See id.