What Is the Procedure for Curing Laws That Violate the Single Subject Rule ?
In Loxahatchee River Environmental Control District v. School Board of Palm Beach County, 515 So. 2d 217 (Fla. 1987), this Court explained how laws that violate the single subject rule generally are "cured":
At every odd-year regular session, the legislature, as part of its program of continuing revision, adopts the laws passed in the preceding odd year as official statute laws and directs that they take effect immediately under the title of "Florida Statutes" dated the current year.
In Santos v. State, 380 So. 2d 1284 (Fla. 1980), this Court held that when laws passed by the legislature are adopted and codified in this manner, the restrictions of article III, section 6, pertaining to one subject matter and notice in the title no longer apply. Accord State v. Combs, 388 So. 2d 1029 (Fla. 1980). . . .
. . . a law passed in violation of the requirements of article III, section 6, is invalid until such time as it is reenacted for codification into the Florida Statutes. See Thompson v. Intercounty Tel. & Tel. Co., 62 So. 2d 16 (Fla. 1952).
The Preface to the official Florida Statutes illustrates how the biennial adoption process works. Linda S. Jessen, Preface to Florida Statutes at vi (1999);
In essence, the Preface explains that, during the biennial adoption process, the Legislature amends sections 11.2421, 11.2422, 11.2424, and 11.2425, Florida Statutes, to prospectively adopt as the official statutory law of Florida those portions of the statutes that are carried forward from the preceding regular edition of the Florida Statutes.
Thus, it is clear that the general rule for "curing" laws that violate the single subject rule is through the biennial adoption process.