At a special session called by the executive to consider, among other matters, a bill "providing for the validation of bonds issued by a municipality under sufficient popular vote regardless of technical requirements," the legislature enacted a statute permitting validation of bonds even when issued without legal power, and the bill was approved by the governor. Pursuant to the statute, the common council of Detroit, in order to refund the city's bonded debt, approved the validity of the old obligations of the municipality, and petitioned for a writ of mandamus to compel the city controller to issue the refunding bonds voted for. Held, that the writ should be denied on the ground that the validation law was not included within the governor's message and therefore it violated the provision of the Michigan Constitution which requires that "no bill shall be passed at a special session of the legislature or any other subjects than those expressly stated in the governor's proclamation or submitted by special message." Smith v. Curran, 268 Mich. 366, 256 N. W. 453 (1934).
STATUTES- CONSTITUTIONAL LAW - LEGISLATIVE ACTION AT SPECIAL SESSION LIMITED BY GOVERNOR'S MESSAGE,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol33/iss5/16