Bayne v. Secretary of State

This case concerns the interplay between two amendments to the Constitution of Maryland made within a year of each other more than sixty years past. One, proposed by Acts 1914, ch. 673 and ratified at the election of 2 November 1915, added art. XVI and created “The Referendum.” The other, the “budget amendment,” proposed by Acts 1916, ch. 159 and ratified at the 1916 election, added § 52 to art. Ill and established a comprehensive executive budget system for the State of Maryland, including the requirement that “[e]very appropriation bill shall be either a Budget Bill, or a Supplementary…