Court Invalidates Proposed Amendment Because It Performed Both Legislative and Judicial Functions

In Evans v. Firestone, 457 So. 2d 1351 (Fla. 1984), the court invalidated a proposed amendment because it performed both legislative and judicial functions. See 457 So. 2d at 1354. The court noted that substantive provisions were essentially legislative, and that the amendment's effect on procedural rules was judicial in nature. See id. Similarly, in People's Property Rights Amendments, the court invalidated an initiative because of its effect not only on "legislative appropriations and statutory enactments but executive enforcement and decision-making." 699 So. 2d at 1308. We further noted that the amendment was violative of the single-subject requirement because "the state, special districts, and local governments have various legislative, executive, and quasi-judicial functions which are applicable to land use." (Advisory Opinion to the Attorney General re People's Property Rights Amendments Providing Compensation for Restricting Real Property Use May Cover Multiple Subjects, 699 So. 2d 1304, 1306 (Fla. 1997)).