Planned Parenthood of Alaska v. Campbell

1. I agree with the majority that the superior court correctly concluded that omis*735sions in the initiative petition summary rendered it inaccurate.1 I write further on this point to emphasize that regardless of an initiative’s subject matter, if the initiative regulates conduct and creates criminal penalties for a violation of the new code of conduct, the petition summary must, as a matter of law, generally describe both the regulated conduct and the potential penalties for misconduct. Any purported regulation of conduct must include consequences, otherwise it is meaningless; the penalties for…