Referendum: The Appropriations Exception in Nebraska: \u3ci\u3eLawrence v. Beermann\u3c/i\u3e, 192 Neb. 507, 222 N.W.2d 809 (1974)

The referendum process has been defined as “the submission of laws . . . to the voting citizens for their ratification or rejection, ” these laws first having been passed upon by the people\u27s representatives. The Nebraska Constitution excludes only one type of statute from submission to the referendum process: “those making appropriations for the expense of the state government or a state institution existing at the time of the passage of such act” (Nebraska Constitution, Article III, section 3). Recent passage and submission to the referendum process of Legislative Bill 772, which established and funded a system of increased state aid to public schools, emphasized the difficulty in determining when the exception of Article III, section 3 applies to a particular statute. This problem was addressed by the Nebraska Supreme Court in Lawrence v. Beermann. This Note considers the court\u27s analysis of the issues and the implications of the decision for future legislation