What problems did the Idaho AG flag with the proposed Idaho marijuana decriminalization ballot initiative?

Plain-English summary

Petitioner Jackee Winters filed a marijuana decriminalization initiative with the Idaho Secretary of State on September 19, 2024. The initiative proposed adding a new section to Idaho's Uniform Controlled Substances Act (Title 37, Chapter 27) that would exempt possession, production, and cultivation of marijuana for personal use from criminal penalties, subject to three conditions: personal use only (no sale or resale), no public consumption, and the possessor must be at least 21. AG Raúl Labrador's office (with Deputy Attorney General John C. McKinney drafting) issued the statutory § 34-1809 Certificate of Review on October 18, 2024.

The Cert flagged a long list of drafting problems. The most consequential:

1. "Cannabis" vs. "marijuana" inconsistency. The title used "cannabis" but the body used "marijuana," and Idaho's statutory definition of marijuana excludes parts of the cannabis plant (§ 37-2701(u)(1)–(2)). Idaho's single-subject rule (Idaho Const. art. III § 16) requires the title to track the body. Recommendation: use "marijuana" throughout.

2. "Home cultivation" in title only. The title referred to "home cultivation" but the body said only "cultivation." Either add "home" to the body or remove "home" from the title.

3. "Limited personal production" in title only. The title implied a quantity cap. The body set no cap. Either add a cap to the body or strip "limited" from the title.

4. No quantity limits = direct conflict with felony statutes. Because the body sets no limit on how much marijuana a person can possess, produce, or cultivate "for personal use," it creates head-on conflict with § 37-2732(a)(1) (felony delivery of any amount) and § 37-2732B(a)(1) (trafficking thresholds: 1+ pounds → 1-yr mandatory minimum; 5+ → 3-yr; 25+ → 5-yr). The Cert notes that to make the initiative work, statutory exceptions to delivery and trafficking would have to be enacted, and writes that "that task involves more that this Review can accommodate": a polite way of saying the initiative as drafted would create irresolvable conflict with the rest of Title 37 ch. 27.

5. Section-numbering errors. The initiative tried to add a new "Section 37-2752A" (and its heading also said "37-2752"), but those numbers fall in Article VI of Chapter 27, which is for housekeeping (pending proceedings, uniformity of interpretation, short title). The Cert recommends placing the new section as § 37-2732E, which would put it in line with the other penalty / prohibited-conduct statutes. (Footnote: § 37-2732D was added July 1, 2024 for fentanyl trafficking, so the next number is 37-2732E.)

6. Vagueness on the "one ounce / 1,000 mg" limit. The body limits transportation to one ounce of plant or 1,000 mg of THC, but says nothing about whether those limits also apply to personal use or cultivation. The Cert flags this under the "void for vagueness" doctrine (Walsh v. Swapp Law, Haw v. Idaho State Bd. of Med.).

7. Fragmentary drug paraphernalia subsection. Section 2 of the initiative would add a subsection (4) to § 37-2734 reading, in full: "Except as provided for in I.C. 37-2752A." That is a sentence fragment with no operative clause. If the intent is to exempt people exercising the new marijuana rights from drug paraphernalia liability, it needs to say so explicitly.

8. Federal law unaffected. Even if the initiative passes, marijuana remains a Schedule I controlled substance under federal law. Federal prosecutors retain authority to bring federal charges (Oakland Cannabis Buyers' Coop.), and federal employment / housing rules tied to federal illegality still apply. The Cert cites Assenberg (housing) and Emerald Steel (employment) as illustrative.

Plus a side note: the requested Long Ballot Title used "does not support" while the body used "[n]othing in this section shall be construed to allow." The Cert says "support" is ambiguous (could mean neutral or could mean opposed), and recommends matching the body's clearer "shall be construed to allow" language.

Severability clause: the only thing the Cert blesses without modification.

What this means for you

If you are drafting an Idaho marijuana decriminalization (or any drug-reform) initiative

• Pick one term and use it everywhere. Idaho statutes use "marijuana"; using "cannabis" in your title and "marijuana" in your body invites a single-subject rule challenge under Idaho Const. art. III § 16.
• Set explicit quantity limits in the body. No-limit possession or cultivation will collide with § 37-2732 and § 37-2732B trafficking thresholds. If you want any quantity to be legal for personal use, write it explicitly. If you want to displace trafficking law for personal-use quantities, say so explicitly with cross-references.
• Number the new section in the right place. Put a new criminal-exception in Article IV (alongside § 37-2732), not Article VI.
• Write complete subsections. "Except as provided for in [other section]" is not a subsection; it is a fragment.
• Spell out the relationship to drug paraphernalia. If your decriminalization is to be meaningful in practice, write the paraphernalia carve-out as an operative clause, not as a stub.
• Be explicit about whether quantity caps apply to use, cultivation, and transportation, or just to one of those. The "one ounce / 1,000 mg" ambiguity in this petition is a model of what to avoid.
• Don't oversell to voters. Federal law, employment law, and housing law all remain. A successful state-law decriminalization would not give Idahoans a federal defense, an employment-protection right, or housing-law immunity.

If you are an Idaho voter looking at a future marijuana decriminalization measure

This Cert is a checklist of what to look for. A clean future initiative should: use a consistent term, set explicit quantity limits, expressly exempt drug-paraphernalia liability for the legalized conduct, and explain the relationship to existing trafficking and delivery felonies. If a measure on your ballot does not address those points, the legal effects of passing it will be uncertain.

If you are a criminal defense attorney in Idaho watching this measure

The Cert is a near-roadmap of which provisions of Title 37 Chapter 27 would still apply if this initiative passed unmodified, and which would conflict. Felony delivery (§ 37-2732(a)(1)) and trafficking (§ 37-2732B(a)(1)) would survive without explicit carve-outs. Drug paraphernalia (§ 37-2734) would survive too, since the proposed subsection (4) does not actually do anything. So even with an "exemption from penalties" in Chapter 27, your client could still face felony delivery, trafficking, and paraphernalia charges: making the practical decriminalization much narrower than voters might think.

If you are an Idaho employer or landlord

Even if Idaho voters were to enact this initiative, federal Schedule I status of marijuana remains. Federally-funded housing, federal employment-related rules, and federal contractor obligations are tied to federal law. The Cert cites Assenberg (federally-funded housing) and Emerald Steel (employment under federal-illegality framing) as examples. Your federal-law obligations are unchanged.

Common questions

Q: Did this initiative reach the ballot?
A: This Cert is part of pre-circulation review under § 34-1809. Whether the initiative was modified, signature gathering succeeded, and it reached the ballot is a separate question. Check the Idaho Secretary of State's records for the petition's status.

Q: Why does the AG care about whether the title and body use the same word?
A: Because Idaho Const. art. III § 16 says the body of an act can be void to the extent its subject is not "expressed in the title." A mismatch invites a constitutional challenge to the parts of the act not covered by the title.

Q: What is "single-subject rule"?
A: Article III § 16 requires every act to "embrace but one subject and matters properly connected therewith, which subject shall be expressed in the title." It applies to legislation and to citizen initiatives because they produce ordinary statutes.

Q: What's the difference between "decriminalization" and "legalization"?
A: This initiative was framed as decriminalization: exemption from criminal penalty for personal-use possession, cultivation, and production. Legalization typically also covers commercial sale, dispensary licensing, and tax. This initiative explicitly excluded sale and resale.

Q: Does federal Schedule I status make Idaho's potential decriminalization meaningless?
A: No. State decriminalization changes the rules under state law, including state criminal prosecutions (which are far more numerous than federal ones). But it leaves federal authority intact. The Cert's takeaway: whatever Idaho does, federal law continues to apply.

Q: Is the AG opposed to marijuana decriminalization?
A: The Cert explicitly disclaims any policy view: "This office offers no opinion with regard to the policy issues raised by the proposed initiative." The flags are about drafting and legality, not about whether the policy is good or bad.

Background and statutory framework

§ 34-1809 governs the AG's pre-circulation review of citizen initiatives. The review is "advisory only," and the petitioner is free to accept or reject the recommendations.

Title 37 Chapter 27 of the Idaho Code is the Uniform Controlled Substances Act. Within Chapter 27, Article IV contains penalty and prohibited-conduct provisions (§§ 37-2732 to 37-2732D). § 37-2734 covers drug paraphernalia. Marijuana is defined in § 37-2701(u), with statutory exclusions for certain plant parts.

Federal law treats marijuana as a Schedule I controlled substance under the Controlled Substances Act (21 U.S.C. § 812(c)). State decriminalization under principles of dual sovereignty does not affect federal authority (Wheeler, Marek, Oakland Cannabis Buyers' Coop.). Federal-law-tied rules in housing and employment continue to apply (Assenberg, Emerald Steel).

Single-subject rule: Idaho Const. art. III § 16 requires every act (including initiatives) to "embrace but one subject and matters properly connected therewith, which subject shall be expressed in the title."

Void-for-vagueness doctrine: a statute that "either forbids or requires the doing of an act in terms so vague that people of common intelligence must necessarily guess at its meaning and differ as to its application violates the first essential of due process of law" (Walsh v. Swapp Law, quoting Haw).

Citations and references

Statutes:
- Idaho Code § 34-1809 (initiative review)
- Idaho Code § 37-2701, § 37-2701(u) (definition of marijuana)
- Idaho Code § 37-2732, § 37-2732(a)(1) (delivery)
- Idaho Code § 37-2732B(a)(1) (trafficking thresholds)
- Idaho Code § 37-2732D (fentanyl trafficking, added 2024)
- Idaho Code § 37-2734 (drug paraphernalia)
- Idaho Const. art. III § 16 (single-subject rule)

Cases:
- Walsh v. Swapp Law, PLLC, 166 Idaho 629, 462 P.3d 607 (2020)
- Haw v. Idaho State Bd. of Med., 140 Idaho 152, 90 P.3d 902 (2004)
- United States v. Wheeler, 435 U.S. 313 (1978)
- State v. Marek, 112 Idaho 860, 736 P.2d 1314 (1987)
- United States v. Oakland Cannabis Buyers' Coop., 532 U.S. 483 (2001)
- Assenberg v. Anacortes Housing Authority, 268 Fed. Appx. 643 (9th Cir. 2008)
- Emerald Steel Fabricators, Inc. v. Bureau of Labor & Industries, 230 P.3d 518 (Or. 2010)

Source

• Landing page: https://www.ag.idaho.gov/office-resources/opinions/
• Original PDF: https://www.ag.idaho.gov/content/uploads/2024/10/24-93561-Response-COR.pdf

Original opinion text

Best-effort transcription from a scanned PDF. Minor errors may remain — the linked PDF is authoritative.

STATE OF IDAHO
OFFICE OF THE ATTORNEY GENERAL
RAUL R. LABRADOR

October 18, 2024

The Honorable Phil McGrane
Idaho Secretary of State
Statehouse
VIA HAND DELIVERY

Re: Certificate of Review
Proposed Initiative

Dear Secretary of State McGrane:

An initiative petition was filed with your office on September 19, 2024. Pursuant to Idaho Code § 34-1809, this office has reviewed the petition and has prepared the following advisory comments. Given the strict statutory timeframe within which this office must review the petition, our review can only isolate areas of concern and cannot provide in-depth analysis of each issue that may present problems. Further, under the review statute, the Attorney General's recommendations are "advisory only." The petitioners are free to "accept them in whole or in part." Due to the available resources and limited time for performing the reviews, we did not communicate directly with the petitioner as part of the review process. The opinions expressed in this review are only those that may affect the legality of the initiative. This office offers no opinion with regard to the policy issues raised by the proposed initiative.

BALLOT TITLES

Following the filing of the proposed initiative, this office will prepare short and long ballot titles. The ballot titles should impartially and succinctly state the purpose of the measure without being argumentative and without creating prejudice for or against the measure. While our office prepares titles for the initiative, petitioners may submit proposed titles for consideration. The advisory comments below address the proposed titles included in the initiative petition. This does not mean, however, that our office agrees with the substance of the proposed titles or that this office will ultimately use the proposed titles if the proposed initiative is filed.

MATTERS OF SUBSTANTIVE IMPORT

A. Summary of the Initiative

The Initiative is self-titled "Initiative Decriminalizing Cannabis, Called 'Marijuana' Or 'Marihuana' As Defined In Title 37-2701(U), For Personal Use, Home Cultivation, And Limited Personal Production." Primarily, the Initiative seeks to amend title 37, Idaho Code, by adding a new sub-section to Chapter 27, Prop. I.C. § 37-2752A, which declares that persons who are engaged in the possession, production or cultivation of marijuana and marijuana-infused products are exempt from the penalties prescribed by Chapter 27. The Initiative also seeks to amend Chapter 27 with a new sub-section, Prop. I.C. § 37-2734A(4), which apparently seeks to exclude conduct described in Prop. I.C. § 37-2752A from being deemed illegal under the drug paraphernalia statutes.

B. Legal and Practical Concerns

This review will involve, among other matters, the "single-subject rule" of the Idaho Constitution. It states: "Every act shall embrace but one subject and matters properly connected therewith, which subject shall be expressed in the title[.]" Idaho Const. art. III, § 16. The constitutional provision continues, "but if any subject shall be embraced in an act which shall not be expressed in the title, such act shall be void only as to so much thereof as shall not be embraced in the title." Id. In short, a title must accurately summarize what is contained in the body of the Initiative, and the body of the Initiative must reflect what is in the title.

1. Requested Title

The "Requested Title" reads in full: "Decriminalize Cannabis Now." Although "cannabis" also appears in the Requested Short Ballot Title and the Requested Long Ballot Title, it is not mentioned anywhere in the body of the Initiative. Instead, "marijuana" is employed in the body of the Initiative. Also, cannabis is not exactly the same as Idaho's statutorily defined "marijuana," which excludes various parts of the "plant genus Cannabis." See I.C. § 37-2701(u)(1)&(2). Therefore, it is recommended that "cannabis" be replaced with "marijuana" throughout the Initiative.

2. Requested Short Ballot Title

The "Requested Short Ballot Title" of the Initiative states:

Initiative Decriminalizing Cannabis, Called "Marijuana" Or "Marihuana" As Defined In Title 37-2701(U), For Personal Use, Home Cultivation, And Limited Personal Production.

The word "marijuana" should be used instead of "cannabis" since "marijuana" is the word used in the body of the Initiative. It is suggested that the first part of the Short Ballot Title read: "Initiative Decriminalizing Marijuana (or 'Marihuana') as Defined in ...."

Although the Requested Short Ballot Title states that one of the Initiative's purposes is to allow for "home cultivation," the body of the Initiative only refers to "cultivation." If the Initiative is intended to provide for home cultivation, it should say that in its body. If not, the Short Ballot Title should have the word "home" excised.

The reference to "limited personal production" in the Short Ballot Title is confusing because it suggests there would be a limit placed on the quantity of marijuana that can be personally produced. The body of the Initiative does not provide for any limits on the quantity of such production; therefore, the word "limited" should be excised from the Short Ballot Title, or, alternatively, the body of the Initiative should set out the quantity of marijuana that can be personally produced.

3. Requested Long Ballot Title

For the same reasons discussed above, the "Requested Long Ballot Title" should replace "cannabis" with "marijuana." Next, either the Long Ballot Title should excise the word "home" before "cultivation," or add the word "home" before "cultivation" in the body of the Initiative. As stated above, article III, § 16, of the Idaho Constitution states, "if any subject shall be embraced in an act which shall not be expressed in the title, such act shall be void only as to so much thereof as shall not be embraced in the title." Therefore, it is important that the body of the Initiative include what is stated in the Title, and that the Title accurately describe the main aspects of the body of the Initiative.

The Requested Long Ballot Title concludes with the following sentence:

This Initiative Does Not Support Private Or Commercial Sale Or Resale Of Cannabis Or Cannabis Derived Products, Nor Does It Support Transportation Of Cannabis Or Cannabis Derived Products That Exceed One Ounce Of Plant Or 1000MG Of THC.

While the above statement appears to roughly summarize Prop. I.C. § 37-2752A(2), there is a slight difference in meaning between its comment that the Initiative does not support certain conduct, and the body of the Initiative's statement that "[n]othing in this section shall be construed to allow" such conduct. The "support" phrases in the Requested Long Ballot Title give no clue as to how the Initiative does not support the conduct described — it could be saying that it is neutral about the conduct, or it could indicate opposition to such conduct. The statement in the body of the Initiative — "[n]othing in this section shall be construed to allow" — is more definitive. Therefore, it is recommended that the language used in Prop. I.C. § 37-2752A(2) be used in the Requested Long Ballot Title.

4. Section 1 Heading

The heading for "Section 1" of the Initiative states that it is amending Title 37, Chapter 27, of the Idaho Code with a new section "to be known and designated as Section 37-2752," later citing the new section as Section 37-2752A. Both statutory designations are incorrect. I.C. § 37-2748 through I.C. § 37-2751 fall within Article VI of Chapter 27, which relates to pending proceedings, continuation of rules, uniformity of interpretation, and naming a "Short title" for Chapter 27 as the "Uniform Controlled Substances Act." The Prop. I.C. §§ 37-2752 and 37-2752A do not logically fall within those provisions. Instead, it is recommended that the Initiative designate its proposed new statute under Article IV as Prop. I.C. § 37-2732E which would place it in line with statutes relating to penalties and prohibited acts involving controlled substances. (Footnote: I.C. § 37-2732D (trafficking in fentanyl) was added to the Uniform Controlled Substances Act, effective July 1, 2024. Therefore, the next addition to I.C. § 37-2732 should be I.C. § 37-2732E.)

5. Sub-Section (1) of Section 1

Sub-section (1) of Section 1 states in full:

Possession, production, or cultivation of Marijuana or Marijuana-infused products are exempted from penalties imposed by this Chapter if: (a) such Marijuana is for personal use and not for sale or resale; (b) is not consumed in any public or open setting; (c) is in the possession of a person who is at least 21 years old.

The above sub-section exempts "from penalties" under the Uniform Controlled Substances Act (i.e., Chapter 27) the use, possession, production, or cultivation of marijuana and marijuana-infused products. There are only three limitations. Such substances must be "for personal use and not for sale or resale," and must possessed by a person at least 21 years of age.

Most significantly, there is no limitation on the amount of marijuana (weight or number of plants) that may be possessed, produced, or cultivated — as long as it is possessed by a person at least 21 years of age, and is for personal use, not sale or resale.

Because there is no quantity limitation on how much marijuana can be possessed, produced, or cultivated under Prop. I.C. § 37-2752A, that proposed statute would directly conflict with the following controlled substances felony laws:

Delivery of a controlled substance — I.C. § 37-2732(a)(1) which makes it a felony to deliver any amount of marijuana, whether for sale or not.

Trafficking in marijuana — I.C. § 37-2732B(a)(1) — by knowingly being in actual or constructive possession of marijuana in the following quantities:

(A) One pound or more, but less than five pounds, or 25 to 49 plants — one year mandatory minimum fixed sentence;
(B) Five pounds or more but less than 25 pounds, or 50 to 99 plants — three-year mandatory minimum fixed sentence;
(C) 25 pounds or more, or 100 or more plants — five-year mandatory minimum fixed sentence.

In order to accommodate the new laws created by the Initiative, statutory exceptions to the above delivery and trafficking laws would have to be enacted. That task involves more that this Review can accommodate.

Sub-section 1 does not address whether children or adults under 21 years of age may be in proximity to, or contact with, marijuana that is possessed, produced, or cultivated by a person 21 years of age or older. Such proximity or contact could negatively impact those under 21, especially children.

Next, there are no restrictions on where marijuana can be cultivated or produced — it is only the consumption of marijuana that cannot be done in "any public or open setting." Although the Requested Short Ballot Title mentions "home cultivation," there is no such limitation in the body of the Initiative. Therefore, the cultivation and production of marijuana can be done apart and away from a person's home — as long as it is for personal use and not for sale or re-sale.

6. Sub-Section (2) of Section 1

In sub-section (2) of Section 1, the Initiative states:

Nothing in this section shall be construed to allow private or commercial sale or resale of any controlled substance nor transportation in quantities that exceed one ounce of plant or 1,000 mg of THC in other Marijuana derived or infused products.

The first part of the above sentence states that private and commercial sales and resales of controlled substances are prohibited. Since the Initiative relates to marijuana, it merely reiterates that the Initiative does not allow for the sale or resale of marijuana or other marijuana derived or infused products. The second part of the above-quoted provision appears to allow for the transportation of up to one ounce of marijuana and up to 1,000 mg of THC in other marijuana derived or infused products. The thrust of this would be to allow persons to transport, or carry with them, a relatively small amount of marijuana (etc.) for personal use.

Although the "one ounce" and "1,000 mg" limits seem to apply to "personal use" as well as transportation, they do not appear in sub-section (1) of Section 1 in regard to "personal use," making it unclear if they do. Such a lack of clarity could subject the provision to a constitutional challenge based on the "void for vagueness" principle. That principle is that "a statute which either forbids or requires the doing of an act in terms so vague that people of common intelligence must necessarily guess at its meaning and differ as to its application violates the first essential of due process of law." Walsh v. Swapp Law, PLLC, 166 Idaho 629, 641, 462 P.3d 607, 619 (2020) (quoting Haw v. Idaho State Bd. of Med., 140 Idaho 152, 157, 90 P.3d 902, 907 (2004)). It is recommended that the Initiative clarify whether the two limitations apply to the "personal use" of marijuana (etc.).

7. Section 2

Section 2 of the Initiative seeks to add a new sub-section, sub-section (4), to I.C. 37-2734. The entirety of the proposed new sub-section reads, "Except as provided for in I.C. 37-2752A."

Sub-sections (1) through (3) of I.C. § 37-2734 pertain to drug paraphernalia. Adding a new sub-section (4) would not make any sense, as the statute would read in full:

(1) It is unlawful for any person to use, or to possess with intent to use, drug paraphernalia to plant, propagate, cultivate, grow, harvest, manufacture, compound, convert, produce, process, prepare, test, analyze, pack, repack, store, contain, conceal, inject, ingest, inhale, or otherwise introduce into the human body a controlled substance.

(2) It is unlawful for any person to place in any newspaper, magazine, handbill, or other publication any advertisement, knowing, or under circumstances where one reasonably should know, that the purpose of the advertisement, in whole or in part, is to promote the sale of objects designed or intended for use as drug paraphernalia.

(3) Any person who is in violation of the provisions of subsections (1) and/or (2) of this section is guilty of a misdemeanor and upon conviction may be imprisoned for not more than one (1) year, fined not more than one thousand dollars ($1,000), or both.

(4) Except as provided for in I.C. 37-2752A.

The proposed sub-section is a dead-end which explains nothing. If the intent of the Initiative is to exclude those who are in legal possession of marijuana (etc.) under Prop. I.C. § 37-2752A from being punished for possessing or using drug paraphernalia, it does not accomplish that task. Assuming such intent, the proposed sub-section (4) to I.C. § 37-2734A should clearly state that persons whose conduct falls within the scope of Prop. I.C. § 37-2752A cannot be punished for possessing, with the intent to use, drug paraphernalia under subsection (1).

8. Severability

The severability clause reads:

The provisions of this initiative hereby declared to be severable if any provision of this initiative the application of such provision to any person of circumstance is declared invalid for any reason, such declaration shall not affect the validity of the remaining portions of this initiative.

The Severability clause appears to be appropriately worded and legally proper.

C. If Enacted, the Initiative Would Have No Legal Impact on Federal Criminal, Employment, or Housing Laws Regarding Marijuana

Idaho is free to enforce its own laws, just as the federal government is free to do the same. See United States v. Wheeler, 435 U.S. 313, 317 (1978) (superseded by statute); State v. Marek, 112 Idaho 860, 865, 736 P.2d 1314, 1319 (1987). Under the concept of "separate sovereigns," the State of Idaho can create its own criminal laws and exceptions pertaining to the use of marijuana. However, the State of Idaho cannot limit the federal government, as a separate sovereign, from prosecuting marijuana related conduct under its own laws. See United States v. Oakland Cannabis Buyers' Coop., 532 U.S. 483, 493-95 (2001). Therefore, passage of the Initiative would not affect the ability of the federal government to prosecute marijuana related crimes under federal laws.

The fact that marijuana use remains illegal under federal law may continue to impact Idaho's citizens in additional ways as well. For example, a person's marijuana use might affect the extent to which federal or state housing or employment laws protect that individual. See Assenberg v. Anacortes Housing Authority, 268 Fed. Appx. 643, 644 (9th Cir. 2008) (housing); Emerald Steel Fabricators, Inc. v. Bureau of Labor & Industries, 230 P.3d 518, 520 (Or. 2010) (employment). Thus, the provisions of the Initiative, Prop. I.C. § 37-2752 (or I.C. § 37-2752A), cannot interfere or otherwise have an effect on federal laws, criminal or civil, which rely, in whole or in part, on marijuana being illegal under the federal Controlled Substances Act.

CERTIFICATION

I HEREBY CERTIFY that the enclosed measure has been reviewed for form, style, and matters of substantive import. The recommendations set forth above have been communicated to the Petitioner via a copy of this Certificate of Review, deposited in the U.S. Mail to Jackee Winters, 154 E. Gettysburg St., Boise, ID 83706.

Sincerely,

RAUL R. LABRADOR
Attorney General

Analysis by:

John C. McKinney
Deputy Attorney General