Is a Bill Containing One Subject In the Title, but Two In the Body Valid ?
In Moreau v. Lewis, 648 So. 2d 124, 128 (Fla. 1995), the title of the Implementing Bill contained only one subject, while the body contained two.
Under such circumstances involving appropriations, it is proper to sever the superfluous subject contained in the body of the chapter law if such severance does not violate the rules governing severance set forth in Presbyterian Homes v. Wood, 297 So. 2d 556 (Fla. 1974). Cf. State v. Physical Therapy Rehab. Center of Coral Springs, Inc., 665 So. 2d 1127, 1131-32 (Fla. 1st DCA 1996) (finding title of chapter law unconstitutionally defective for failing to give adequate notice of contents, and severing section in body of the chapter law that was not adequately noticed in the title);
Millard H. Ruud, "No Law Shall Embrace More Than One Subject", 42 Minn. L. Rev. 389, 397 (1958) ("If the title [of a bill] gives adequate notice of a portion of the contents of the bill, then only that portion of the act of which the title fails to give adequate notice is invalid.").