The Illinois Supreme Court recently upheld the constitutionality of legislation involving a $3 billion state construction program funded in part by the legalization of video poker, which would be permitted in bars and restaurants across the state. The legislation was designed to revitalize the state’s economy and would purportedly create more than 400,000 jobs. The dollars generated will also be utilized for school construction projects.

Chicago Blackhawks owner Rocky Wirtz filed suit to challenge the legislation in order to block higher state taxes resulting from the legislation that would impact his family liquor distributorship.

Wirtz argued that the legislation was unconstitutional because the legislation was not limited to a single subject. The single subject clause of the Illinois Constitution provides that bills shall be confined to one subject. The test is whether the provisions in the act have a natural and logical connection to the single subject. Therefore, legislation violates the single subject rule when it contains unrelated provisions that have any legitimate relation to the single subject.