Turnbull v. Fink
Delaware Supreme Court
668 A.2d 1370 (1995)

- Written by Deanna Curl, JD
Facts
The 1989 Bond Act (the act), an appropriations measure, contained over 130 separate appropriations from various state funding sources. Section 68 of the act enacted a separate statutory provision that waived sovereign-immunity protections for state agencies up to the amount of insurance coverage authorized for purchase under the act. In response to a lawsuit by Turnbull (plaintiff), state officials (defendant) asserted that the sovereign-immunity waiver limits enacted under § 68 of the act applied. During an appeal of a trial-court ruling, Turnbull argued for the first time that § 68 violated the single-subject rule of the Delaware Constitution because the act contained more than one subject and the sovereign-immunity waiver provisions enacted by § 68 were not included in the title of the act.
Rule of Law
Issue
Holding and Reasoning (Hartnett, J.)
Dissent (Holland, J.)
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