North Dakota Measure 1: Single-Subject Rule, Vote, and 2026 Distinction

North Dakota’s Measure 1 single-subject rule passed on June 9, 2026, with roughly 66% of voters in favor and 34% opposed.¹ Every proposed amendment to the North Dakota Constitution, whether brought by citizen petition or referred by the legislature, must now address only one subject.²

What the Rule Requires

Measure 1 amends two sections of the state constitution: Section 9 of Article III, which governs citizen-initiated constitutional amendments, and Section 16 of Article IV, which governs amendments referred by the Legislative Assembly. Both must now be limited to a single subject.³

Enforcement falls on two offices. The Secretary of State must review citizen initiative petitions before they can be circulated for signatures and reject any that cover more than one subject. The Legislative Assembly is directed to limit its own referred amendments the same way.² Secretary of State Michael Howe has said his office will rely on the North Dakota Attorney General’s Office to make the actual single-subject determinations during petition review.¹

What Changes for Citizen Initiatives

Sponsors of a constitutional initiative in North Dakota already had to clear several steps: form a committee of at least 25 electors, get the petition approved for form by the Secretary of State, collect signatures equal to 4% of the state’s population (about 31,164 signatures), and file at least 120 days before the election.²

Measure 1 adds a new gate at the front of that process. The Secretary of State must now also evaluate whether a proposed amendment meets the single-subject requirement before approving the petition for circulation. A petition that fails the test can be blocked before a single signature is gathered, rather than only after a signature drive is complete.

Why Lawmakers Put It on the Ballot

The measure reached voters through Senate Concurrent Resolution 4007, passed during North Dakota’s 2025 legislative session.² Supporters pressed two main arguments. Rep. Steve Vetter said that “having multiple subjects in one amendment can be misleading and confusing for voters” and that “it is important for people to know what they’re voting on.” Proponents also pointed out that the North Dakota Constitution already requires ordinary bills passed by the legislature to contain only one subject, and said the same standard should apply to changes to the constitution itself.⁴

A 2023 North Dakota Supreme Court ruling gave the push urgency. In Board of Trustees of the North Dakota Public Employees Retirement System v. North Dakota Legislative Assembly, the court struck down Senate Bill 2015, the state’s Office of Management and Budget budget bill, for violating the existing single-subject rule for legislation. The bill’s title ran 630 words, and its 68 sections touched everything from school funding to fertilizer production to controlled substance laws. The court found that calling the subject “state government operations” was so broad it would effectively erase the single-subject requirement from the constitution.⁵ Governor Doug Burgum then called an emergency special session to restore the voided appropriations.⁶

Reform advocates also pointed to earlier citizen-initiated amendments. Marsy’s Law, a victims’ rights measure backed by out-of-state funding, was described by the Fargo Forum as a “horribly written victim’s rights law” and became a flashpoint for concerns about complex, outside-funded initiatives reshaping the state constitution. Medical marijuana legalization and a sweeping ethics commission measure were cited as further examples of initiatives that bundled broad or multiple topics into one vote.⁷

This was not the legislature’s first try. In 2024, voters rejected Measure 2, which included a single-subject rule but also required 60% voter approval and a second confirming vote for constitutional amendments.⁴ The 2026 version was stripped down to the single-subject change alone.

Arguments Against

Critics said the rule would make it harder for ordinary citizens to get amendments on the ballot and tilt the process toward the legislature. Bismarck voter Patrick Clancy said the measure “kind of takes the voice away from people that are trying to put out a particular initiative.”⁸

Opponents also argued that “single subject” is inherently subjective. Because the Secretary of State can now refuse to allow a petition to circulate at all, critics warned the new rule creates something close to an executive veto over citizen amendments, with the potential for politically motivated decisions and costly litigation.⁸

Vote and Turnout

Measure 1 was the only statewide ballot measure on the June 9, 2026, primary ballot.³ The Minot Daily News reported the final margin at 77,072 votes in favor to 38,955 opposed.⁹ The measure needed only a simple majority and carried no estimated fiscal impact.²

Statewide primary turnout was low, at about 21%. Roughly 125,000 voters cast ballots, with 41% voting early or absentee and 59% voting on Election Day. County turnout ranged from 55% in rural Billings County to just 12% in Grand Forks County.¹⁰

Not the Same as November 2026’s Measure 1

The June primary’s Measure 1 is a different proposal from the Constitutional Measure 1 on North Dakota’s November 2026 general election ballot. The November version would raise the threshold for passing future constitutional amendments from a simple majority to 60%. It became “Measure 1” for November only after the North Dakota Supreme Court ruled on June 25, 2026, that a separate term limits proposal (Senate Concurrent Resolution 4008) was unconstitutional and ordered it removed, prompting the Secretary of State to renumber the remaining measures.¹¹ The June single-subject rule controls what future amendments can contain; the November measure, if approved, would control how hard they are to pass.

1
News From the States. North Dakota Voters Adopt Single-Subject Rule for Constitutional Measures
2
North Dakota Secretary of State. June 2026 Ballot Measure Guide
3
North Dakota Secretary of State. Measures on the Ballot
4
North Dakota Monitor. Lawmakers Approve Ballot Measure Putting Single-Subject Rule to Statewide Vote
5
FindLaw. Board of Trustees of the North Dakota Public Employees Retirement System v. North Dakota Legislative Assembly
6
Office of the Governor, State of North Dakota. Burgum Calls Special Session of Legislature to Address Bill Ruled Unconstitutional by ND Supreme Court
7
North Dakota Legislative Branch. Testimony on SCR 4013
8
North Dakota Monitor. North Dakota Voters Favor Single-Subject Rule for Constitutional Measures in Early Results
9
Minot Daily News. ND Voters Approve Single-Subject Rule
10
North Dakota Monitor. Voter Turnout in North Dakota at About 21% for Primary
11
North Dakota Monitor. North Dakota Supreme Court Tosses Ballot Measure, Finding Term Limits Proposal Unconstitutional