Legal Definitions - enrolled-bill rule

The enrolled-bill rule is a legal principle that states once a legislative bill has been officially passed by both houses of the legislature, signed by the presiding officers, and approved by the executive (such as the Governor or President), it is considered to be the final, accurate, and authoritative version of the law. This rule creates a strong presumption that the law was enacted correctly and reflects the legislature's true intent. Consequently, courts generally will not investigate alleged procedural errors or mistakes that might have occurred during the bill's journey through the legislative process, such as claims that a word was accidentally omitted or an amendment was improperly added or removed. The primary purpose of this rule is to ensure stability and certainty in the law, preventing endless challenges to the validity of statutes based on internal legislative procedures.

Here are some examples illustrating the enrolled-bill rule:

• Example 1: Accidental Drafting Error

  Imagine a state legislature passes a bill designed to streamline the permitting process for small businesses. After the Governor signs it into law, a business advocacy group discovers that a crucial phrase, "unless otherwise specified," was accidentally left out of a key section during the final drafting, significantly altering the scope of the new regulations. The group attempts to challenge the law in court, arguing that the omission was a clear mistake and does not reflect the legislature's true intent.

  Under the enrolled-bill rule, a court would likely refuse to invalidate the law based on this alleged drafting error. The officially signed and enrolled version of the statute is presumed to be correct and complete, regardless of claims about what was intended or what might have been accidentally omitted during its creation. The court would interpret the law as it is written in the final, authenticated document.

• Example 2: Disputed Procedural Irregularity

  Consider a scenario where a new state budget bill is enacted into law. A watchdog organization later alleges that during a late-night legislative session, a specific amendment adding funding for a controversial project was passed without the required number of votes, or that a committee meeting where a significant change was made lacked the necessary quorum. The organization seeks to have that specific funding provision, or even the entire budget, declared invalid.

  The enrolled-bill rule would typically prevent a court from overturning the budget law based on these alleged procedural irregularities. Once the bill has been officially enrolled, signed by the legislative leaders, and approved by the Governor, courts generally defer to the legislature's final product. The rule assumes that all internal legislative procedures were properly followed, and courts will not typically "go behind" the enrolled bill to investigate such claims, thereby upholding the stability of the budget law.

• Example 3: Lost Amendment Claim

  Suppose a bill concerning environmental protection passes through the legislature and is signed into law. An environmental advocacy group later claims that an amendment, which would have imposed stricter limits on industrial pollution, was approved by the House of Representatives but somehow disappeared from the bill before it was sent to the Senate for a final vote and subsequently to the Governor for signature. The group argues that the final law is incomplete and does not reflect the full will of the legislature.

  A court applying the enrolled-bill rule would likely uphold the law as it was signed by the Governor, even if there is some evidence suggesting an amendment was indeed lost or removed improperly. The enrolled version of the statute is considered definitive. Courts generally will not delve into the legislative history to reconstruct what should have been included or what might have been the legislature's full intent, prioritizing the final, authenticated text of the law.