Why did the Arkansas Attorney General reject the first version of the proposed amendment that would have repealed the Pope County casino license and required local voter approval for new casinos?
Apply this to your situation
This page answers the general question as of 2024. Ezel answers yours: what it means for your facts, under current Arkansas law, with citations.
Plain-English summary
Elizabeth Robben Murray submitted the first version of a proposed amendment that would have (1) repealed Amendment 100's authorization for a Pope County casino, (2) required voter approval in a county-wide special election for any future casino license outside Crittenden, Garland, and Jefferson counties, and (3) made the amendment effective November 13, 2024.
The AG rejected the popular name and ballot title:
Primary defect: incorporation by reference. The measure's text said that, when a future amendment authorized a casino in a new county, the quorum court must call a special election "in accordance with Arkansas Code Annotated §§ 7-11-201 et seq. and 7-11-301 et seq." This is incorporation of statutes into the constitution by reference. Arkansas's "full-text" requirement under Amendment 7 (Article 5, § 1) requires the full text of the proposed measure to accompany each petition. Incorporating statutes by reference violates this rule because voters cannot read the full text of what they are being asked to enshrine in the constitution.
The AG cited Haugen v. Jaeger (N.D. 2020) and Dyer v. Hall (N.D. 1924), recognizing that the Arkansas Supreme Court has not directly ruled but would likely agree with North Dakota's longstanding rule against incorporation by reference. The AG also reaffirmed his analysis from prior opinions (Ark. Att'y Gen. Ops. 2023-133 and 2023-113).
Secondary defects flagged for the sponsor's revision:
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Popular name length. The original was longer than typical popular names. AG suggested shortening.
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Effect on issued Pope County casino licenses. The text was silent on what happens to a casino license already issued before the amendment's effective date. Voters need to know if the amendment voids existing licenses or just bars future ones.
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Current casino licenses in Jefferson County. Crittenden and Garland Counties had specific named licensees in the text (Southland and Oaklawn). Jefferson County did not. Was the omission intentional? Voters need to know.
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Missing summaries in the ballot title. Several material provisions did not appear in the title: reduction of casino licenses from four to three, repeal of Racing Commission authority specifically, the prerequisite that voters approve before applications can be accepted, and the specific ballot format for special elections.
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Grammatical issues. "Or" used instead of "of"; lack of grammatical parallelism in the ballot title.
The sponsor revised and the second version was certified in Opinion 2024-046.
What this means for you
Ballot initiative sponsors and constitutional drafters
Two big lessons:
First, do not incorporate statutes by reference. If you want a process from a statute to operate within your amendment, copy the operative language into the amendment's text. Yes, that bloats the text. Yes, it requires more care. But it is the only way to comply with Arkansas's full-text requirement. The AG is firm on this point.
Second, summarize every material change. The AG flagged four substantive provisions missing from the title. The Bailey v. McCuen "essential facts" rule is unforgiving: omission of material provisions is misleading, and post-election challenges based on omission are well-trodden ground. If your amendment touches a complex statutory framework, plan for a long ballot title (and accept the litigation risk that comes with it).
Election law attorneys
The Haugen v. Jaeger discussion is notable. The Arkansas Supreme Court has not directly addressed incorporation by reference in initiated measures. The AG signals that if the question reaches the Court, the AG will argue Haugen is correct: incorporation by reference defeats the full-text requirement's purpose of letting voters see exactly what they are voting for. That position is now AG record across multiple opinions.
Casino industry observers
The Pope County casino dispute had been litigated for years by the time of this 2024 opinion. The proposed amendment was an effort to settle it constitutionally by repealing the authorization and barring future Pope County licenses. The first version's drafting defects delayed certification, but the second version (certified in Opinion 2024-046) addressed them. Track the substantive policy outcome: did the second version make the ballot, and did it pass? (It did not appear on the November 2024 ballot.)
Pope County residents
The legal status of a Pope County casino remained contested at the time of this opinion. The proposed amendment, even if certified and on the ballot, would have needed voter approval to take effect. The amendment did not advance to the November 2024 ballot, so the existing constitutional framework (Amendment 100 authorizing four casinos including one in Pope County) remained in effect.
Common questions
What's the "full-text requirement"?
Article 5, § 1 of the Arkansas Constitution (Amendment 7) requires that the "full text" of an initiated measure accompany each petition. A.C.A. § 7-1-107 requires sponsors to give the AG the full text of the proposed measure. The purpose: voters must be able to read what they are signing on for, without having to look up external statutes or other sources.
Does the AG's reading of the full-text requirement bind the Arkansas Supreme Court?
No. The AG is a member of the executive branch; the Court will reach its own conclusion if a sponsor pushes back. But the AG cited the long-standing North Dakota Supreme Court holdings (Dyer v. Hall, 1924; Haugen v. Jaeger, 2020) interpreting a similar provision the same way. If the Arkansas Supreme Court reaches the question, the AG's position is well supported by sister-state authority.
Did Murray resubmit?
Yes. Opinion 2024-046 certified the revised version, which copied the relevant special-election procedure into the amendment's text rather than incorporating it by reference, and which addressed the other concerns flagged here.
What was the Pope County casino backstory?
Amendment 100 (passed November 2018) authorized four casino licenses (Crittenden, Garland, Jefferson, Pope). Crittenden, Garland, and Jefferson got their licenses promptly. The Pope County license was contested through years of litigation between Cherokee Nation Businesses, Gulfside Casino Partnership, and others, with delays and lawsuits at the Racing Commission and in court. The 2024 amendment was an attempt to resolve the dispute by repealing the Pope County authorization.
Are there opinions about other proposals to incorporate statutes by reference?
Yes. Ark. Att'y Gen. Ops. 2023-133 and 2023-113, both cited in this opinion, applied the same analysis to different proposals. The AG has been consistent across multiple sponsors.
Background and statutory framework
Full-text requirement. Ark. Const. art. 5, § 1 (Amendment 7) requires the "full text" of an initiated measure to accompany each petition. A.C.A. § 7-1-107 requires sponsors to provide the AG with the full text.
AG ballot-title review. A.C.A. § 7-9-107 sets the process; § 7-9-107(d)(1) authorizes substitution; § 7-9-107(e) authorizes rejection.
Roberts v. Priest doctrine. Roberts v. Priest, 341 Ark. 813, 20 S.W.3d 376 (2000), holds that ambiguities in the measure's text can prevent any ballot title from being legally certified.
Bailey "essential facts" rule. Bailey v. McCuen, 318 Ark. 277, 884 S.W.2d 938 (1994), holds that omission of essential facts that would give voters serious ground for reflection is misleading.
Cited authority on incorporation by reference. Haugen v. Jaeger, 2020 N.D. 177, 948 N.W.2d 1 (North Dakota Supreme Court); Dyer v. Hall, 51 N.D. 391, 199 N.W. 754 (1924) (North Dakota Supreme Court).
Cited statutes the proposal would have incorporated by reference. A.C.A. §§ 7-11-201 et seq. and 7-11-301 et seq. (Arkansas special-election procedures).
Amendment 100. Passed November 2018. Authorized four casino licenses in Crittenden, Garland, Jefferson, and Pope counties.
Citations
- A.C.A. § 7-9-107 (AG ballot-title review)
- A.C.A. § 7-9-107(d)(1) (substitute and certify)
- A.C.A. § 7-9-107(e) (rejection authority)
- A.C.A. § 7-1-107 (full-text submission requirement)
- A.C.A. §§ 7-11-201 et seq., 7-11-301 et seq. (special-election procedures the proposal incorporated by reference)
- Ark. Const. art. 5, § 1 (Amendment 7, full-text requirement)
- Roberts v. Priest, 341 Ark. 813, 20 S.W.3d 376 (2000)
- Bailey v. McCuen, 318 Ark. 277, 884 S.W.2d 938 (1994)
- Haugen v. Jaeger, 2020 N.D. 177, 948 N.W.2d 1
- Dyer v. Hall, 51 N.D. 391, 199 N.W. 754 (1924)
- Ark. Att'y Gen. Ops. 2023-133, 2023-113 (prior incorporation-by-reference rejections)
Source
Original opinion text
Opinion No. 2024-034
March 4, 2024
Elizabeth Robben Murray, Attorney
Friday, Eldredge & Clark LLP
400 West Capitol Avenue, Suite 2000
Little Rock, Arkansas 72201
Dear Ms. Murray:
I am writing in response to your request, made under A.C.A. § 7-9-107, that I certify the
popular name and ballot title for a proposed constitutional amendment.
My decision to certify or reject a popular name and ballot title is unrelated to my view of
the proposed measure’s merits. I am not authorized to consider the measure’s merits when
considering certification.
- Request. Under A.C.A. § 7-9-107, you have asked me to certify the following popular
name and ballot title for a proposed initiated amendment to the Arkansas Constitution:
Popular Name
A constitutional amendment requiring local voter approval in a countywide
special election for any new casino licenses and repealing authority to issue
a casino license in Pope County, Arkansas.
Ballot Title
An amendment to the Arkansas Constitution, Amendment 100, § 4,
subsections (i) through (n), repealing the authorization for a casino in Pope
County, Arkansas, and repealing authority to issue a casino license in Pope
County, Arkansas; and an amendment to the Arkansas Constitution,
Amendment 100 § 4, to add subsection (s), requiring local voter approval
in a countywide special election where a casino license is to be issued with
the exception of casino licenses now or hereafter issued for casinos in
Crittenden (to Southland Racing Corporation), Garland (to Oaklawn Jockey
Club, Inc.) and Jefferson Counties; making this Amendment effective on Ms. Elizabeth Robben Murray
Opinion No. 2024-034
Page 2
and after November 13, 2024; providing that the provisions of this
Amendment are severable in that if any provision or section of this
Amendment or the application thereof to any person or circumstance is held
invalid, such invalidity shall not affect any other provision or application
that can be given effect without the invalid provision or application; and
repealing all laws or parts or laws in conflict with this Amendment. - Rules governing my review. Arkansas law requires sponsors of statewide initiated
measures to “submit the original draft” of the measure to the Attorney General.1 An
“original draft” includes the full text of the proposed measure along with its ballot title and
popular name.2 Within ten business days of receiving the sponsor’s original draft, the
Attorney General must respond in one of three ways:
• First, the Attorney General may approve and certify the ballot title and popular
name in the form they were submitted.3
• Second, the Attorney General may “substitute and certify a more suitable and
correct ballot title and popular name.”4 But A.C.A. § 7-9-107 does not authorize
the Attorney General to modify the text of the proposed measure itself.
• Third, the Attorney General may reject both the popular name and ballot title “and
state his or her reasons therefor and instruct” the sponsors to “redesign the proposed
measure and the ballot title and popular name.”5 This response is permitted when,
after reviewing the proposed measure, the Attorney General determines that “the
ballot title or the nature of the issue” is (1) “presented in such manner” that the
ballot title would be misleading or (2) “designed in such manner” that a vote for or
against the issue would actually be a vote for the outcome opposite of what the
voter intends.6 - Rules governing the popular name. The popular name is primarily a useful legislative
device.7 While it need not contain detailed information or include exceptions that might be
1 A.C.A. § 7-9-107(a).
2 A.C.A. § 7-9-107(b).
3 A.C.A. § 7-9-107(d)(1).
4 Id.
5 A.C.A. § 7-9-107(e).
6 Id.
7 Pafford v. Hall, 217 Ark. 734, 739, 233 S.W.2d 72, 75 (1950). Ms. Elizabeth Robben Murray
Opinion No. 2024-034
Page 3
required of a ballot title, the popular name must not be misleading or partisan.8 And it must
be considered together with the ballot title in determining the ballot title’s sufficiency.9 - Rules governing the ballot title. The ballot title must summarize the proposed act. The
Arkansas Supreme Court has developed general rules for what must be included in the
summary and how that information must be presented. Sponsors must ensure their ballot
titles impartially summarize the measure’s text and give voters a fair understanding of the
issues presented.10 The Court has also disapproved the use of terms that are “technical and
not readily understood by voters.”11 Ballot titles that do not define such terms may be
deemed insufficient.12
Additionally, sponsors cannot omit material from the ballot title that qualifies as an
“essential fact which would give the voter serious ground for reflection.”13 Yet the ballot
title must also be brief and concise lest voters exceed the statutory time allowed to mark a
ballot.14 The ballot title is not required to be perfect, nor is it reasonable to expect the title
to address every possible legal argument the proposed measure might evoke.15 The title,
however, must be free from any misleading tendency—whether by amplification,
omission, or fallacy—and it must not be tinged with partisan coloring.16 Although the ballot
title need not summarize existing law,17 it must be honest and impartial,18 and it must
convey an intelligible idea of the scope and significance of a proposed change in the law.19
8 E.g., Chaney v. Bryant, 259 Ark. 294, 297, 532 S.W.2d 741, 743 (1976); Moore v. Hall, 229 Ark. 411, 414–
15, 316 S.W.2d 207, 208–09 (1958).
9 May v. Daniels, 359 Ark. 100, 105, 194 S.W.3d 771, 776 (2004).
10 Becker v. Riviere, 270 Ark. 219, 226, 604 S.W.2d 555, 558 (1980).
11 Wilson v. Martin, 2016 Ark. 334, 9, 500 S.W.3d 160, 167 (citing Cox v. Daniels, 374 Ark. 437, 288 S.W.3d
591 (2008)).
12 Id.
13 Bailey v. McCuen, 318 Ark. 277, 285, 884 S.W.2d 938, 942 (1994).
14 A.C.A. §§ 7-9-107(d)(2) (requiring the ballot title “submitted” to the Attorney General or “supplied by the
Attorney General” to “briefly and concisely state the purpose the proposed measure”), 7-5-309(b)(1)(B)
(allowing no more than ten minutes); see Bailey, 318 Ark. at 288, 884 S.W.2d at 944 (noting the connection
between the measure’s length and the time limit in the voting booth).
15 Plugge v. McCuen, 310 Ark. 654, 658, 841 S.W.2d 139, 141 (1992).
16 Bailey, 318 Ark. at 284, 884 S.W.2d at 942 (internal citations omitted); see also Shepard v. McDonald,
189 Ark. 29, 70 S.W.2d 566 (1934).
17 Armstrong v. Thurston, 2022 Ark. 167, 10, 652 S.W.3d 167, 175.
18 Becker v. McCuen, 303 Ark. 482, 489, 798 S.W.2d 71, 74 (1990).
19 Christian Civic Action Comm. v. McCuen, 318 Ark. 241, 250, 884 S.W.2d 605, 610 (1994). Ms. Elizabeth Robben Murray
Opinion No. 2024-034
Page 4
The Court has held that a proposed measure that expressly states that it “will repeal
inconsistent laws” is sufficient to inform the voters “that all laws which are in conflict will
be repealed.”20
Finally, the Court has held that a ballot title cannot be approved if the text of the proposed
measure itself contributes to confusion and disconnect between the language in the popular
name and the ballot title and the language in the measure.21 Where the effects of a proposed
measure on current law are unclear or ambiguous, I am unable to ensure the popular name
and ballot title accurately reflect the proposal’s contents until the sponsor clarifies or
removes the ambiguities in the proposal itself. - Application. Having reviewed the text of your proposed initiated amendment, as well
as your proposed popular name and ballot title, I have concluded that I must reject your
proposed popular name and ballot title and instruct you to redesign them. The following
problems in the text of your proposed amendment prevent me from (1) ensuring your
ballot title is not misleading or (2) substituting a more appropriate ballot title:22
Under Section 2 of your measure’s text, when “a constitutional amendment authorizes or
otherwise allows the issuance of a casino license for any county other than those issued
now or hereafter for Crittenden…Garland…and Jefferson counties, then the county
quorum court shall call a special election in accordance with Arkansas Code Annotated §§
7-11-201 et seq. and 7-11-301 et seq.” It appears you are attempting to incorporate-by-
reference state statutes into the constitution by referencing the statutes’ citations.
This violates the full-text requirement and is misleading by omission. A voter reviewing
your ballot title would not be sufficiently advised about the content of the statutes you are
attempting to incorporate. Amendment 7 (Ark. Const., art. 5, § 1) to our state constitution
requires that the “full text” of the initiated measure accompany each petition.
Consequently, under A.C.A. § 7-1-107, all sponsors must give the Attorney General “[t]he
full text of the proposed measure.” And while the Arkansas Supreme Court has yet to
interpret the meaning of the phrase “full text of the proposed measure,” the North Dakota
Supreme Court recently reviewed a substantially identical phrase in law.23 In Haugen v.
20 Richardson v. Martin, 2014 Ark. 429, 9, 444 S.W.3d 855, 861.
21 Roberts v. Priest, 341 Ark. 813, 825, 20 S.W.3d 376, 382 (2000).
22 Although A.C.A. § 7-9-107 does not authorize the Attorney General to modify the text of the proposed
measure itself, the Attorney General still reviews the text of the proposed measure because the ballot title
and popular name cannot be certified when the “text of the proposed amendment itself” is ambiguous or
misleading. Roberts, 341 Ark. at 825, 20 S.W.3d at 382. And in line with the caselaw, my predecessors have
consistently rejected ballot titles “due to ambiguities in the text” of the proposed measure. E.g., Ark. Att’y
Gen. Ops. 2016-015, 2015-132, 2014-105, 2014-072, 2013-079, 2013-046, 2013-033, 2011-023, 2010-007,
2009-083, 2008-018, 2005-190, 2002-272, 2001-397, 2001-129, 2001-074, 2000-084, 1999-430.
23 I have also recently reviewed in detail the holding of this particular North Dakota Supreme Court decision
in Ark. Att’y Gen. Ops. 2023-133, 2023-113, and I incorporate that analysis by reference here. Ms. Elizabeth Robben Murray
Opinion No. 2024-034
Page 5
Jaeger, the North Dakota Supreme Court reviewed the legal validity of an initiated
constitutional amendment that, by explicit citation, incorporated certain statutes into the
state constitution.24 There, the legal question was whether such an incorporation violated
the state’s full-text requirement.
Reaffirming a nearly 100-year-old decision on that topic of law, Dyer v. Hall,25 the Haugen
court held that such an incorporation by reference violates the full-text requirement for two
reasons. First, it cut against “the purpose of the full-text requirement,” which “was to
obviate all uncertainty as to the subject-matter dealt with in the Constitution.”26 Second,
Haugen approvingly cited Dyer’s additional point that when initiated measures incorporate
laws by reference, the “voters have no opportunity to read or examine fairly the contents
[of those incorporated laws] and appreciate the real import of the proposed amendment.”27
In my opinion, the Arkansas Supreme Court likely would agree with Haugen’s conclusion
and reasoning when interpreting our own full-text requirements.
Here, you, like the sponsors in Haugen, expressly incorporate by reference statutes into the
process governing county quorum courts under your measure’s text. Therefore, voters
reviewing the ballot title are not sufficiently advised about the content of the statute you
are attempting to incorporate into your measure’s text, and the absence of the measure’s
full text means the ballot title is misleading by omission.
Because of the issues identified above, my statutory duty under A.C.A. § 7-9-107(e) is to
reject your proposed popular name and ballot title, stating my “reasons therefor,” and to
“instruct…[you] to redesign your proposed measure and the ballot title…in a manner that
would not be misleading.” - Additional issues. The foregoing defects are sufficient grounds for me to reject your
submission. But please note that your proposed measure contains several other issues that,
while not bases for my decision to reject your proposed measure, you may wish to correct
or clarify:
• Popular name length. Your popular name is longer than a typical popular name. It
instead reads like a brief summary of the ballot title, or a shorter ballot title.
Typically, a popular name is a few words and serves as a label or nametag for the
ballot title and proposed measure.28 Although this alone is not misleading, you may
24 2020 N.D. 177, 948 N.W.2d 1.
25 51 N.D. 391, 199 N.W. 754 (1924).
26 2020 N.D. at 4, 948 N.W.2d at 4 (internal quotations omitted).
27 Id. at 4, 948 N.W.2d at 3 (internal quotations omitted).
28 See, e.g., Ark. Att’y Gen. Ops. 2024-028 (certifying “Arkansas Medical Marijuana Amendment of 2024”);
2024-020 (certifying “The Arkansas Government Disclosure Act of 2024”); 2023-092 (certifying “An Act
to Exempt Feminine Hygiene Products and Diapers from Sales and Use Tax”); 2024-004 (certifying Ms. Elizabeth Robben Murray
Opinion No. 2024-034
Page 6
wish to shorten the popular name to better meet the purpose of popular names as
described above.
• Effect on any issued Pope County casino license. The ballot title and the text of
your proposed measure indicate that the current authority under Amendment 100,
§ 4 to issue a casino license in Pope County is being revoked. And your proposed
measure will instead require a majority of voters in a county, when a casino license
is authorized or otherwise allowed by a constitutional amendment, to approve of a
casino at a special election, with the exception of casino licenses that have already
been issued or may later be issued for “Crittenden (to Southland Racing
Corporation), Garland (to Oaklawn Jockey Club, Inc.), and Jefferson counties.” But
nothing in your proposed measure indicates what will happen to a Pope County
casino license that has been issued before the effective date of your proposed
initiated constitutional amendment. If your measure passes and takes effect, will
such a license automatically become void, or will the Racing Commission be
compelled to revoke that license or simply not renew the license after the expiration
date? The answers to these questions likely would give voters “ground for serious
reflection.”
• Current casino licenses. As already noted above concerning Pope County, your
proposed measure also does not indicate whether any license has already been
issued in Jefferson County. Although “Southland Racing Corporation” and
“Oaklawn Jockey Club, Inc.” are both specifically named in their respective
counties, no entity is likewise named for Jefferson County. Does this mean that a
casino has not been issued a license in Jefferson County, or that multiple licenses
may be issued to Jefferson County in a manner not consistent with the other
counties? The answers to these questions likely would give voters “ground for
serious reflection.”
• Ballot title summaries. The Arkansas Supreme Court has interpreted the Arkansas
Constitution to require that sponsors include all material in the ballot title that
qualifies as an “essential fact which would give the voter serious ground for
reflection.”29 But your proposed constitutional amendment contains material
“Arkansas Abortion Amendment”); 2016-080 (certifying “Arkansas Term Limits Amendment”); 2015-083
(certifying “The Campaign Finance Act of 2016”); 2016-029 (certifying “An Amendment to Limit Non-
Economic and Punitive Damages in Civil Medical Care Cases”); 2016-007 (certifying “The Arkansas
Medical Marijuana Amendment of 2016”); 2011-033 (certifying “The Natural Gas Severance Tax Act of
2012”); 1993-011 (certifying “Arkansas Soft Drink Tax Act”); 2007-179 (certifying “Four Year Terms for
Elected County Officials”); 1990-125 (certifying “Insurance Company Reporting Law”); 1980-61 (certifying
“Arkansas Mandatory Referendum on Legislative Tax Measures”); 1978-13 (certifying “Hospital and
Practitioner of the Healing Arts Malpractice Amendment”); but see, e.g., Ark. Att’y Gen. Op. 2016-058
(certifying “An Amendment to Allow Three Casinos in Arkansas, One Each in the Following Counties:
Boone County, Operated by Arkansas Gaming and Resorts, LLC; Miller County, Operated by Miller County
Gaming, LLC; and Washington County, Operated by Washington County Gaming, LLC”).
29 Bailey, 318 Ark. at 285, 884 S.W.2d at 942. Ms. Elizabeth Robben Murray
Opinion No. 2024-034
Page 7
provisions that do not appear in your ballot title, which would likely give voters
“serious ground for reflection” and would render the ballot tile misleading by
omission (all emphases below have been added):
o The ballot title fails to mention that the number of casino licenses the
Arkansas Racing Commission is required to issue would be reduced from
four to three;
o The ballot title fails to mention that, in addition to repealing the
authorization for a casino in Pope County, Arkansas, the proposed measure
would also repeal the authority of the Arkansas Racing Commission to
issue any casino license in Pope County, Arkansas without receiving a
majority of voters in a county where a casino is licensed to approve of a
casino at a special election;
o The ballot title fails to mention that the voters in a county where a future
casino is proposed would need to first approve of a casino at the special
election before the Arkansas Racing Commission, or other governing body,
may accept any applications for a casino license in that county; and
o The ballot title fails to mention that special election ballots must provide
questions that substantially follow a particular format, “FOR a casino in
[ ] County” and “AGAINST a casino in [ ] County,” and, “The
question presented to voters must include whether or not a casino may be
located in the county”—“A casino is defined as a facility where casino
gaming is conducted.”
• Grammatical issues. In the ballot title, the word “or” is used instead of “of” in the
following clause: “and repealing all laws or parts or laws in conflict.” Additionally,
your ballot title does not appear to utilize “parallelism,” or use “grammatically
coordinate structures” to “show the reader how one idea relates to another.”30 For
instance, the word “and” is used twice after semicolons and the first two clauses do
not begin with “ing” words when the remaining clauses begin with “ing” words.
You may wish to correct these issues.
Assistant Attorney General William R. Olson prepared this opinion, which I hereby
approve.
Sincerely,
TIM GRIFFIN
Attorney General
30 Bryan A. Garner, GARNER’S MODERN ENGLISH USAGE 801 (5th ed. 2022).
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