school uniform disagree essay

12+ School Uniform Pros and Cons (For and Against Debate)

Have you ever wondered why some schools require uniforms while others let you wear whatever you want?

It's a hot topic, and people have been arguing about it for a long time. Today, we're not just talking about whether uniforms look cool or not, but we're diving into the psychological impacts they can have on students.

Your school clothes might be doing more than just covering you up; they might be affecting your brain in ways you didn't even think about.

School uniforms are not just about what you wear; they can also influence how you think! In this article, we'll talk about:

• How uniforms can make everyone feel more equal but also less special
• Why they might make it easier to choose what to wear but harder to show who you are
• What psychologists and research tell us about this big school debate

So, put on your thinking cap—uniform or not—and let's explore what experts and studies say about the pros and cons of school uniforms.

School Uniform History

Around the 16th century in England, the first school uniforms weren't even for everyday students like most of us. They were made for charity schools, which were for kids who didn't have much money.

The uniforms were there to help everyone know which kids were from those schools. They were simple and plain, and they made sure everyone looked the same. But as time went on, more and more schools started using uniforms, not just the charity ones.

By the 19th century, the uniform trend had caught on in many other places, including the United States. But the reasons for wearing them started to change.

Schools started thinking: "Hey, if everyone's wearing the same thing, then no one can make fun of someone else's clothes." Or: "If everyone looks neat and tidy, then it's easier to focus on studying." It was around this time that schools began to see uniforms as a way to help students feel more equal and keep distractions away.

Now, fast forward to today. The idea behind school uniforms is kind of like a big salad with lots of ingredients. Some people think they're super helpful for keeping schools safe. Others believe they make it easier to get dressed in the morning without fussing over what to wear. And some just like how they look.

But not everything is rosy. Some folks argue, "Hey, I want to show who I am with my clothes. Why should I wear the same thing as everyone else?" This is especially visible in the way different cliques fit into stereotypes , such as the popular kids wearing bright colors and the goths wearing all black.

Others worry about how much these uniforms might cost, especially for families that might not have a lot of money.

As you can see, the school uniform journey is full of twists and turns, like a wild roller coaster ride. But one thing's for sure: it's not just about fashion; it's also about feelings, thoughts, and how we see ourselves and others.

The whole debate about uniforms also has some big brain stuff behind it. For example, psychologists—those are people who study how our minds work—have had a lot to say about how uniforms might make us feel. Some think they help create a team spirit, while others think they squash our creativity.

No matter which side of the fence you're on, there's no denying that the simple school uniform carries a lot of weight. From its early days in old England to its role in modern schools, the uniform has been a source of comfort for some and conflict for others. As we dig deeper into the pros and cons, we'll uncover even more about this age-old debate.

School Uniform Pros

1) psychological equality.

First on our list is the idea that uniforms can make everyone feel more equal. When you see a whole bunch of kids wearing the same thing, it's tough to know who's got the coolest or most expensive clothes.

Dr. David Brunsma, a sociologist who has written extensively about school uniforms , suggests that this kind of equality can help lower the chances of kids getting picked on or bullied for what they're wearing.

Imagine you're playing a team sport. If everyone's wearing the same jersey, you're all focused on the game, not on who's got the flashiest gear. This is sorta what uniforms do in schools. They can help students focus on what really matters, like learning and making friends, instead of worrying about who's wearing what. This could make it less likely for students to get bullied for their clothes.

2) Reduced Decision Fatigue

Next up is a psychological idea called " decision fatigue ." Ever felt tired from just picking your outfit in the morning? Well, psychologist Roy F. Baumeister talks about how making too many decisions can actually make your brain tired . Having a uniform takes away one choice you have to make, helping you save that brainpower for more important things like schoolwork.

3) Sense of Belonging

Here comes a heartwarming point: uniforms can make you feel like you're part of a team.

Dr. Angela Wright, who has studied the psychology behind uniforms, says that this sense of belonging can make students feel more connected and secure in school. Some research even shows that when kids feel like they fit in, they're more likely to be nice to each other and do well in their classes.

4) Fostering Discipline and Focus

Last but not least, let's talk about discipline. Dr. Alex Rentz, who has researched how uniforms impact student behavior, believes that wearing a uniform can help students focus better. It's like when a firefighter puts on their uniform; they know it's time to get serious and do their job. The same can go for students. That uniform is like a signal to your brain saying, "Hey, it's time to learn!"

So there you have it! These are some of the top reasons why people think school uniforms are a win. But hold your horses! It's not all sunshine and rainbows. In our next section, we're gonna look at why some folks think school uniforms are not so great.

School Uniform Cons

It's time to switch gears and talk about the reasons some people and experts give school uniforms a big thumbs-down. Trust us, it's not just about wanting to wear the latest fashion trends; it's a lot deeper than that, and it has a lot to do with how we think and feel.

1) Suppressing Individuality

Let's kick things off with one of the biggest arguments against school uniforms: they can squash your individuality. Dr. Christopher Lubienski, an education expert, says that uniforms can make it harder for students to express their unique personalities.

When you're stuck wearing the same thing as everyone else, you can't show off your personal style or let the world know a little bit about who you are.

2) Financial Strain

Next, we have to talk about money. Uniforms can cost a lot, and for families that are already tight on cash, this can be a big burden.

Dr. Elaine Schwartz, an economist who has looked into the financial aspects of school uniforms, points out that some families might struggle to pay for these mandatory clothes. And let's not forget about growth spurts; kids can outgrow uniforms quickly, leading to more expenses.

3) Contradicts Freedom of Expression

Now, let's get into some serious business: freedom of expression. This is something that psychologists like Dr. Alan Hilfer have talked about. He says that being able to choose your clothes is a way to express yourself and your opinions. In a country that values freedom, making everyone wear the same thing can feel like a big step backward.

4) Potential for Rebellion

Last on our list, believe it or not, is that uniforms can actually make some students act out. Dr. David L. Brunsma, who we mentioned earlier, also points out that some studies show wearing uniforms can make students feel like they're being controlled too much. And when people feel controlled, they sometimes do the opposite of what's expected, just to show they can.

So there you have it! These are some of the key reasons why some people aren't so hot on the idea of school uniforms. As you can see, it's a debate that brings out strong feelings and arguments from both sides.

Up next, we'll dive into what some important studies and theories have to say about all this.

School Uniform Theories

Let's move on to some studies and theories that have tackled the school uniform debate. These studies help us understand the nitty-gritty of why uniforms can be good or bad.

1) Social Identity Theory

First up, let's talk about something called Social Identity Theory . This was developed by psychologist Henri Tajfel, and it explores how people identify with groups.

When students wear uniforms, they're all part of the same "group," at least in appearance. This can create a sense of unity, but it can also make students feel like they're just one of many, losing their personal identity.

This theory helps us understand the balance between belonging and individuality that uniforms bring into play.

2) Self-Determination Theory

Another important theory is the Self-Determination Theory by psychologists Edward Deci and Richard Ryan.

This theory explains that people need to feel some control over their actions to be happy and successful. For some kids, being told what to wear every day might go against this need for personal control, which can lead to feeling unhappy or even acting out in rebellion, like Dr. David L. Brunsma mentioned in the previous section.

3) Empirical Studies

On the research front, there have been many studies, but let's focus on one by Dr. Jafeth Sanchez and Dr. George Mitchell. They conducted a study on school uniforms and concluded that uniforms didn't seem to significantly impact academic performance, but they did note some improvements in school climate, like fewer fights and less bullying.

4) Cost-Benefit Analyses

Last but not least, economists have done what's called cost-benefit analyses, where they weigh the good and bad sides of uniforms.

Economists like Dr. Elaine Schwartz, who we mentioned earlier, have said that the financial strain of buying uniforms might not always be worth the benefits they bring, especially for low-income families.

So there you have it, folks! From theories that dig deep into our need for belonging and control, to studies that look at how uniforms actually play out in real life, the uniform debate is chock-full of interesting angles. What we've learned is that there's no easy answer. Like a seesaw, the pros and cons keep tipping the scale back and forth.

School Uniforms According to Kids

It's good to know the formal theories, but let's hear from the real experts—kids themselves! After all, they're the ones wearing these uniforms day in and day out. What they say may surprise you!

They Like Being Treated Equally

Many kids actually like wearing uniforms because it levels the playing field. They say it stops "clothing competition" where some kids might show off expensive or fashionable items. In a way, uniforms can act as a great equalizer, making everyone appear the same at first glance.

But it's important to remember that while uniforms might match, accessories or technology, like iphones and laptops, might not. So uniforms don't completely eliminate competition.

They Want to Show Their Style

On the flip side, a lot of kids feel uniforms cramp their style. They want the freedom to show who they are through their clothes. For them, being made to wear the same outfit every day feels like their personal identity is being stifled.

Comfort Matters

Let's not forget about comfort! Many students point out that some uniforms are just not comfortable to wear for a whole school day. Whether it's stiff collars or itchy fabric, comfort is a big deal when you're sitting in class, trying to focus on learning.

A Mix Would Be Nice

Interestingly, some kids propose a compromise: uniforms on some days and casual clothes on others. They think this would blend the best of both worlds—maintaining a sense of equality and discipline while allowing room for personal expression.

It's clear that kids have a lot to say on this topic, and their voices are an important part of this ongoing debate. After all, school is for them, so shouldn't they have a say in what they wear there?

School Uniforms in Media

You can't talk about school uniforms without mentioning how they're portrayed in movies, TV shows, and even books. These media portrayals can shape our views, and they tell us a lot about how society feels about this hot-button issue.

The Classic Image

Think about classic movies or TV shows that feature private schools; you'll probably recall scenes of students in crisp uniforms. This image often portrays uniforms as a symbol of privilege, discipline, or academic excellence.

Shows like " Gossip Girl " or movies like " Dead Poets Society " have ingrained this view in our minds.

The Rebel Stereotype

Then there's the rebellious student, often seen trying to "hack" their uniform. Whether it's by rolling up their skirt, loosening a tie, or adding flashy accessories, this portrayal taps into the idea of uniforms stifling individuality.

It's like the media is saying, "You can't keep young people from expressing themselves."

A Tool for Storytelling

In literature and film, uniforms can serve as a powerful storytelling device. Take "Harry Potter," for example. The Hogwarts robes do more than just enforce equality; they signal belonging to houses and help create the magical atmosphere of the wizarding world.

Social Commentaries

In some instances, media uses uniforms to make a statement. Shows or movies that depict uniforms in a dystopian setting may be commenting on issues of conformity or loss of personal freedom. These portrayals often reflect societal concerns and fuel discussions about the role of uniforms in schools.

Reality TV Insights

Don't forget reality TV! Shows that focus on schools or young people often highlight the uniform debate. Whether it's students discussing their likes or dislikes, or parents grappling with the costs, these shows give us a real-world look into the practical challenges and benefits of uniforms.

The media, through its varied lenses, gives us a rich tapestry of perspectives on school uniforms. It adds another layer to the complex emotional and psychological landscape we've been exploring.

School Uniforms Around the World

The debate about school uniforms isn't just happening in one place; it's a hot topic all around the world. Different countries and regions have their own unique views and rules, and trust us, it's pretty interesting to see how diverse opinions can be.

United States

In the United States, the issue of school uniforms is mostly a local decision. That means individual school districts or even single schools make the choice.

While some schools swear by uniforms, saying they improve discipline and equality, others champion a student's right to self-expression.

United Kingdom

Hop across the pond to the United Kingdom, and you'll find that school uniforms are much more common. In fact, they've been a tradition for centuries. Psychologists like Dr. Angela Wright, who we mentioned before, point out that the British generally see uniforms as a way to foster a sense of community and discipline.

In Japan, school uniforms are not just clothes; they're deeply rooted in culture. Uniforms are a social norm .

The uniforms aim to instill a sense of discipline and are often seen as a rite of passage. Dr. Hiroshi Ota, an expert on Japanese education, notes that the uniform practice in Japan aims to prepare students for a society that values conformity and group harmony.

Down under in Australia, uniforms are pretty common in both public and private schools. The debate there often centers around comfort and the appropriateness of certain uniform items in various weather conditions.

Researchers like Dr. Michaela Pascoe have discussed how the physical comfort of uniforms can impact a student's ability to focus and learn.

France takes a different approach. Uniforms are generally not required in public schools, reflecting the country's emphasis on individual liberty and personal expression. French psychologists often point to the importance of allowing students the freedom to choose as a way to develop their identity.

Whether it's promoting equality, fostering discipline, or encouraging personal freedom, each country has its own reasons and experts weighing in on the matter.

School Uniform Trends and Future Directions

Now that we've taken a good look at the pros, cons, theories, and global perspectives, let's talk about what's trending. Are schools moving toward or away from uniforms? And what cool new ideas are people coming up with?

Trending Toward or Away?

Interestingly, the trend seems to be a bit of both. In the United States, more public schools have started to adopt uniforms, especially in urban areas.

They're following the lead of private schools, which have often required uniforms. But there's a growing voice for more freedom of expression too, which has led some schools to move away from strict uniform policies.

Uniforms with Options

One of the coolest new trends is something called "uniforms with options." This is basically a middle-ground approach that allows students to pick from a range of approved clothing items.

For example, a school might have a color scheme and let students choose any shirts or pants that fit within those colors. Dr. Michelle Birkett, a researcher who has looked into the psychological impacts of such choices, says this allows students to adhere to a standard while still expressing a bit of personal flair.

Tech-Enabled Uniforms

Yes, you heard that right. In some countries, schools are experimenting with uniforms that have tracking devices for safety reasons. However, this has opened up debates on privacy and autonomy.

Dr. Shoshana Zuboff, an expert on surveillance capitalism, warns that this might go against the principles of personal freedom and privacy.

Dress Code Reforms

There's also a trend toward reforming dress codes to be more inclusive, especially for students who don't identify with traditional gender roles.

Schools are starting to allow more flexibility, like letting girls wear pants or boys wear skirts, to be more accommodating. Psychologists such as Dr. Kristina Olson, who studies gender diversity, say this can have a positive impact on mental health and inclusion.

So, the future of school uniforms is anything but dull. With new ideas and trends popping up, it seems like we're headed toward a more balanced and thoughtful approach to what kids wear to school.

One thing's for sure: the debate about school uniforms isn't a simple one . Whether it's psychologists discussing the impact on our minds, or economists weighing the costs, or even kids and parents sharing their everyday experiences, there are a lot of opinions to consider.

What have we learned? Well, for one, uniforms can help with equality and focus, but they can also stifle individuality and put a financial burden on families. Different countries have their unique views, and the future is shaping up to offer more balanced options for students to express themselves while maintaining some level of uniformity.

The conversation about school uniforms is far from over, and it's a debate that will likely continue to evolve. But no matter which side of the fence you're on, it's crucial to keep listening and learning from each other. Because in the end, the goal is the same: to create an environment where every student has the chance to shine, both in and out of their school clothes.

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Do uniforms make schools better?

by: Marian Wilde | Updated: March 1, 2024

Print article

Schools, parents, and students frequently clash over the issue of regulating what students may and may not wear to school. These controversies often pegged to the culture war of the moment touch on everything from gender and sexuality to politics, race, and religion. In 2021, a group of about 50 students in Georgia protested their middle school’s dress code for being discriminatory against BIPOC girls by wearing t-shirts every Friday emblazoned with the words “sexist,” “racist,” and “classist.” In 2022, a fight between students, staff, and police officers broke out at a Pennsylvania high school when hats and hoodies were banned as part of a revision by the school board to the school’s dress code. And in 2023, two Michigan middle schoolers, via their mother, sued their school district after they were banned from wearing “Let’s Go Brandon” sweatshirts.

Are school uniforms the best solution to this contentious debate? If every student is wearing the same outfit, will a host of campus problems be solved? Researchers are divided over how much of an impact — if any — dress policies have on student learning. There are multiple studies with conflicting conclusions, plus books such as 2018’s The Debate About School Uniforms , but the argument wears on, with a list of pros and cons on each side.

Why do some public schools have uniforms?

In the 1980s, public schools were often compared unfavorably to Catholic schools. Noting the perceived benefit that uniforms conferred upon Catholic schools, some public schools decided to adopt a school uniform policy.

President Clinton provided momentum to the school uniform movement when he said in his 1996 State of the Union speech, “If it means teenagers will stop killing each other over designer jackets, then our public schools should be able to require their students to wear school uniforms.”

The pros and cons of school uniforms

According to proponents, school uniforms:.

• Help prevent gangs from forming on campus

• Encourage discipline

• Help students resist peer pressure to buy trendy clothes

• Help identify intruders in the school

• Diminish economic and social barriers between students

• Increase a sense of belonging and school pride

• Improve attendance

Opponents contend that school uniforms:

• Violate a student’s right to freedom of expression

• Are simply a Band-Aid on the issue of school violence

• Make students a target for bullies from other schools

• Are a financial burden for poor families

• Are an unfair additional expense for parents who pay taxes for a free public education

• Are difficult to enforce in public schools

Uniforms vs. dress codes

Schools and districts vary widely in how closely they adhere to the concept of uniformity.

What’s a dress code?

Generally, dress codes are more relaxed than uniform policies. Sometimes, however, dress codes are quite strict with requirements that are potentially viewed as biased based on race or gender. In 2020, two Black male students in Texas, cousins with West Indian heritage, were suspended for wearing dreadlocks in supposed violation of the district’s hair and grooming policy, part of the dress code. The elder one, a senior, was told he couldn’t attend prom or graduation until his dreads were trimmed. In 2022, girls on the track team at an Albany, NY high school were sent home for wearing sports bras at practice.

Uniforms are certainly easier for administrators to enforce than dress codes, largely because the ACLU (American Civil Liberties Union) can be depended upon to protect a student’s “right to express themselves.” The ACLU believes dress codes are often used to, “shame girls, force students to conform to gender stereotypes… punish students who wear political and countercultural messages. Such policies can be used as cover for racial discrimination… Dress codes can also infringe on a student’s religious rights…” To successfully enforce a dress code, insists the ACLU, the school must prove the student’s attire, “is disruptive to school activities.”

The ACLU’s dress code stance is regularly supported by federal courts , like the 2023 lower court ruling in North Carolina that ended a charter school decree that girls couldn’t wear pants to school. ACLU lawyers claimed this violated Title IX because the dress code “discriminated against female students by limiting their ability to fully participate in school activities, such as using the playground.” The U.S. Supreme Court later declined to take up a case challenging the lower court’s ruling.

Check with your school to see what the dress code is, as they can be fairly specific. In Tulsa, Oklahoma, for example, the dress code prohibits :

• Symbols, mottoes, words or acronyms that convey crude, vulgar, profane, violent, death-oriented, gang-related, sexually explicit, or sexually suggestive messages.
• Symbols, mottoes, words or acronyms advertising tobacco, alcohol, or illegal drugs or drug paraphernalia.
• Symbols, mottoes, words or acronyms identifying a student as a member of a secret or overtly antisocial group or gang or that identifies a student as a member of an organization that professes violence or hatred toward one’s fellow man.
• Visible and permanent tattoos/brands incompatible with the standards set forth herein shall be covered to prohibit their display.
• Excessively large or baggy clothes

What’s a uniform?

School uniforms worldwide can widely range from nondescript to bizarre. (Extreme examples from China, Australia, and the UK on this YouTube video ) Most public school outfits in the USA are quite casual, with a “ common type ” for boys often a polo shirt in a solid color, with pants in khaki, black, or navy blue. A girl’s uniform is often a skirt and a white buttoned-up shirt. Dress shoes are frequently required for both genders.

In the United States, low-income families spend an average of $249 on a child’s school uniform annually, far less than the typical Australian student’s $578. But still, the cost is sometimes viewed as unfair because public education is intended to be free, paid by tax dollars, not “a stress for families on lower incomes.” The ACLU believes that public schools should provide free school uniforms , because the expense is unconstitutional, and it increases wealth inequity.

What research says about school uniforms

In 2006, Virginia Draa, professor at Youngstown State University, reviewed the impact of school uniforms at 64 public high schools that had larger percentages of economically disadvantaged and minority students than other urban schools. Her conclusion surprised her: “I really went into this thinking uniforms don’t make a difference, but I came away seeing that they do… I was absolutely floored.” Her analysis determined that the schools with uniforms improved their students attendance, and graduation rates rose an average almost 11 percent.

In 2022, Ohio State University and University of Pennsylvania researchers reached a contrary opinion in their report titled “ School Uniforms and Students Behavior: Is There a Link? ” Their view was that, in general, evidence that school uniforms improve social skills in the students was “inconclusive.” The solitary praise they provided to uniform-wearing was noting there was “some indication that low-income students in schools that required uniforms demonstrated better school attendance than low-income students in schools that did not.”

What to believe? Jury is still out.

What do students think about uniforms?

A student discussion: pros and cons of uniforms

Editor’s note: This video is part of our high school milestones series about communication skills. The students in this video discuss the pros and cons of school uniforms.

A University of Nevada, Reno, survey of 1,848 middle school students, published in 2022, revealed that 90 percent did not like wearing a uniform to school . Only 30 percent believed the uniforms “might reduce discipline issues, a mere 17 percent thought the uniform helped them focus at school, 34 percent believed their school was safer due to the uniforms and 37 percent said, “I worry less about my appearance” due to the uniform requirement.”

An earlier study, also in Nevada, displayed similar unpopularity with newly instituted uniforms among middle school students. However, when the researchers looked into school discipline and local police records and compared them to the prior year’s data, discipline referrals were down 10 percent, there were 63 percent fewer police log reports, and incidences of graffiti, fights, and gang-related activity were all down.

It’s a big issue

A new trend is the mounting pressure to establish dress codes for teachers. Apparently, the same casual mindset toward revealing outfits is cropping up in the ranks of our teachers.

The debate over uniforms in public schools encompasses many larger issues than simply what children should wear to school. It touches on issues of school improvement, freedom of expression, and hot-button culture wars. It’s no wonder the debate rages on.

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Expert Commentary

School uniforms: Do they really improve student achievement, behavior?

This updated collection of research looks at how mandatory school uniforms impact student achievement, attendance and behavior as well as the presence of gangs in public schools.

Republish this article

This work is licensed under a Creative Commons Attribution-NoDerivatives 4.0 International License .

by Denise-Marie Ordway, The Journalist's Resource April 20, 2018

This <a target="_blank" href="https://journalistsresource.org/education/school-uniforms-research-achievement/">article</a> first appeared on <a target="_blank" href="https://journalistsresource.org">The Journalist's Resource</a> and is republished here under a Creative Commons license.<img src="https://journalistsresource.org/wp-content/uploads/2020/11/cropped-jr-favicon-150x150.png" style="width:1em;height:1em;margin-left:10px;">

Decades ago, uniforms were mostly worn by students who went to private or parochial schools. But as local school boards have focused more on improving standardized test scores and campus safety, a growing number have begun requiring school uniforms — typically, a polo shirt of a particular color paired with navy or khaki pants, skirts or shorts. Nearly 22 percent of public schools in the United States required uniforms in 2015-16 — up from almost 12 percent in 1999-2000, according to the National Center for Education Statistics (NCES).

Proponents argue that students will pay more attention to their classwork if they aren’t preoccupied with fashion, and that they’ll be better behaved. Meanwhile, school administrators say uniforms help eliminate gang-related styles and logos. They also make it easier to spot a stranger on campus.

Despite their reported benefits, mandatory uniforms are controversial because a lot of parents and students don’t like the idea of forcing children to dress alike, which they say suppresses freedom of expression. Some families complain about the financial burden of purchasing uniforms in addition to their kids’ other clothing. Years ago, parents also complained that it was difficult to find uniforms, but that ceased to be an issue after large chain stores like Target and Wal-Mart began selling them.

As public schools debate the merits of uniforms — some school boards have been bouncing the idea around for years — it’s important for journalists to know what the research says on this topic. School officials do not always consult academic research before they put a plan on the table.

To help journalists ground their reporting and fact-check claims, Journalist’s Resource has rounded up several academic studies worth reviewing. Reporters may also want to examine reports on uniform use from the NCES, which collects and reports data related to school uniforms, dress codes and book bags in public schools.

——————————–

 “School Discipline, School Uniforms and Academic Performance” Baumann, Chris; Krskova, Hana. International Journal of Educational Management , 2016. DOI: 10.1108/IJEM-09-2015-0118.

Summary: This study examines test scores and student behavior in the United States, Canada and 37 other countries to determine whether uniforms affect student discipline. The researchers found that the highest-performing students are the most disciplined. In addition, “for countries where students wear school uniforms, our study found that students listen significantly better, there are lower noise levels, and lower teaching waiting times with classes starting on time.”

“Dressed for Success? The Effect of School Uniforms on Student Achievement and Behavior” Gentile, Elizabetta; Imberman, Scott A. Journal of Urban Economics , 2012, Vol. 71. doi: 10.1016/j.jue.2011.10.002.

Abstract: “Uniform use in public schools is rising, but we know little about how they affect students. Using a unique dataset from a large urban school district in the southwest United States, we assess how uniforms affect behavior, achievement and other outcomes. Each school in the district determines adoption independently, providing variation over schools and time. By including student and school fixed-effects we find evidence that uniform adoption improves attendance in secondary grades, while in elementary schools they generate large increases in teacher retention.”

“Uniforms in the Middle School: Student Opinions, Discipline Data, and School Police Data” Sanchez, Jafeth E.; Yoxsimer, Andrew; Hill, George C. Journal of School Violence , 2012. DOI: 10.1080/15388220.2012.706873.

Summary: Researchers asked students at an urban middle school in Nevada what they thought of having to wear uniforms. Their public school had adopted a uniform policy after staff members became frustrated with the earlier dress code policy, which resulted in girls wearing revealing clothing and boys wearing shirts with inappropriate messages and images. The study’s main takeaway: The vast majority of students said they dislike uniforms, although some agreed there were benefits. “For example, in reference to gender, more than expected females than males indicated students treated them better with uniforms. Also, fewer females than males got detention for not wearing a uniform or for wearing a uniform inappropriately.”

“Are School Uniforms a Good Fit? Results from the ECLS-K and the NELS” Yeung, Ryan. Educational Policy , 2009, Vol. 23. doi: 10.1177/0895904808330170.

Abstract: “One of the most common proposals put forth for reform of the American system of education is to require school uniforms. Proponents argue that uniforms can make schools safer and also improve school attendance and increase student achievement. Opponents contend that uniforms have not been proven to work and may be an infringement on the freedom of speech of young people. Within an econometric framework, this study examines the effect of school uniforms on student achievement. It tackles methodological challenges through the use of a value-added functional form and the use of multiple data sets. The results do not suggest any significant association between school uniform policies and achievement. Although the results do not definitely support or reject either side of the uniform argument, they do strongly intimate that uniforms are not the solution to all of American education’s ills.”

“Effects of Student Uniforms on Attendance, Behavior Problems, Substance Use, and Academic Achievement” Brunsma, David L.; Rockquemore, Kerry A. The Journal of Educational Research , 1998, Vol. 92. doi: 10.1080/00220679809597575.

Abstract: “Mandatory uniform policies have been the focus of recent discourse on public school reform. Proponents of such reform measures emphasize the benefits of student uniforms on specific behavioral and academic outcomes. Tenth-grade data from The National Educational Longitudinal Study of 1988 was used to test empirically the claims made by uniform advocates. The findings indicate that student uniforms have no direct effect on substance use, behavioral problems, or attendance. Contrary to current discourse, the authors found a negative effect of uniforms on student academic achievement. Uniform policies may indirectly affect school environment and student outcomes by providing a visible and public symbol of commitment to school improvement and reform.”

“School Uniforms, Academic Achievement, and Uses of Research” Bodine, Ann. The Journal of Educational Research , 2003, Vol. 97. doi: 10.1080/00220670309597509.

Abstract: “School uniforms are being advocated for a range of social, educational, economic, and familial reasons. In 1998, The Journal of Educational Research (The JER) published an article by D. Brunsma and K. Rockquemore that claims that uniforms correlate negatively with academic achievement, but data presented in this article actually show positive correlation between uniforms and achievement for the total sample, and for all but 1 school sector. Examination of structure of argument reveals that the erroneous claim results from misleading use of sector analysis. Simultaneous with The JER article, and on the basis of the same National Education Longitudinal Study: 1988 database, an Educational Testing Service article reported that no correlation exists between uniforms and achievement. The two articles are contrasted in this study. The effect of new communication technology in amplifying political uses of academic research is discussed.”

“Public School Uniforms: Effect on Perceptions of Gang Presence, School Climate, and Student Self-Perceptions” Wade, Kathleen Kiley; Stafford, Mary E. Education and Urban Society , 2003, Vol. 35. doi: 10.1177/0013124503255002.

Abstract: “This study attempts to clarify the relationships between public school uniforms and some of their intended results: student self-worth and student and staff perceptions of gang presence and school climate. The instruments used in the study included a questionnaire on gang presence and identity, the National Association of School Principals Comprehensive Assessment of School Environments, and the Harter Self-Perception Profile for Children. Participants consisted of 415 urban public middle school students and 83 teachers. Findings indicate that, although perceptions did not vary for students across uniform policy, teachers from schools with uniform policies perceived lower levels of gang presence. Although the effect size was small, students from schools without uniforms reported higher self-perception scores than students from schools with uniform policies. Student and teacher perceptions of school climate did not vary across uniform policy.”

“The Effect of Uniforms on Nonuniform Apparel Expenditures” Norum, Pamela S.; Weagley, Robert O.; Norton, Marjorie J. Family & Consumer Sciences , 1998. doi: 10.1177/1077727X980263001.

Abstract: “The uniform industry has grown steadily the past 20 years with increased attention from employers trying to create a professional image among workers as well as school administrators considering uniforms to curtail school violence. Although an important part of human dress for centuries, uniforms have received little attention from researchers of the clothing market. This study examines the impact of uniform purchases on household expenditures for selected nonuniform apparel subcategories based on an economic model of conditional demand. Expenditure equations are estimated using the 1990-1991 Consumer Expenditure Survey. The results suggest that, on average, consumers do not substitute uniforms for other apparel purchases. Rather, uniforms and nonuniform apparel appear to be complements in consumers’ purchases, resulting in greater household expenditures on nonuniform apparel. These results are a first step in understanding the economic effect that uniform purchases, mandated by employers, schools, or others, have on household clothing expenditures.”

Looking for more research on student achievement? Check out our write-ups on how teacher salaries , school vouchers and school shootings impact learning.   

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Home Essay Examples Education School Uniform

School Uniform: Pros And Cons Arguments

• Category Education
• Subcategory School
• Topic School Uniform

Schools requiring a uniform suggest numerous conversation starters for guardians and students. School outfits can profit the learning condition, yet can likewise give a few issues to students all through the school day. School uniforms are accepted to be a practice that dates to the sixteenth century in the United Kingdom. It is accepted that the Christ Hospital School in London in 1552 was the primary school to utilize a school uniform. Students were given a uniform that most outstandingly comprised of a long blue coat and yellow, knee-high socks. A practically indistinguishable uniform is as yet worn by students going to school today. Uniforms for government-funded school students aren’t new, in any case. During the most recent quite a while, numerous schools the nation over – maybe including yours- – have executed clothing standards. The discussion over garbs and clothing standards is likewise recognizable. Supporters state they improve order and increment students’ scholastic achievement. Rivals state they encroach on students’ established right of self-expression and don’t address schools’ genuine issues. However, I think that wearing a school uniform is a must for a student because it helps to build an identity, saves time, avoids harassment, and prepares students for a working place.

Individuals who contradict school dress and clothing standards regularly contend that such measures abuse students’ right to freedom of speech. They attest that how an individual dress is a sort of self-expression, and that the state as the government-funded educational system can’t lawfully mention to students what to wear but wearing a uniform can produce a sense of community or unity in a school. At the point when school uniforms are required, all students are relied upon to dress the equivalent, paying little heed to their style inclinations or financial status. Uniforms can counteract jealousy and disappointment among students, as there is no gazing at originator dresses or taunting of second-hand shop clothes. Rather than utilizing youngsters as strolling bulletins for different brands, uniforms guarantee that everybody has dressed the equivalent, making a situation of fairness.

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School clothing standards have confronted lawful difficulties on First Amendment grounds. In an Indiana claim, guardians sued a school for sending their youngster home for wearing a gold stud earring whereas, at a school in Boston, a clothing standard was set up trying to decrease design rivalry among students. Teachers felt that a few students were increasingly inspired by brand names and who was and wasn’t wearing them than in homework. They likewise proposed that the strategy would set aside teenagers and guardians cash by making it pointless, at any rate at school, to dress to intrigue. Moreover, when there are dress codes set, the pupils can focus more on their studies instead of focusing on what to wear the next day.

Another argument school uniform opposers make is that the uniforms hide the individuality of the children, but is visible that different types of clothing have become a cause for social conflicts. Children who are poorly dressed may face bullying because of the clothes they wear. Many children feel like they are being judged based on the clothes they wear. But, it is confirmed that school uniforms will eliminate this fear among the students and may relieve students.

Some people argue that wearing a school dress might be uncomfortable for a child because children feel more comfortable while wearing clothes made from a specific material whereas school uniforms are universal in quality. So, it may be comforting to some and uncomfortable to others. However, the benefit of school uniforms is that they are very cost-efficient. They’re much cheaper compared to their branded counterparts. Uniforms can be easily and more frequently washed. Parents do not have to spend money every week or two on their children’s new clothes.

While some people argue that wearing a school uniform does not have any connection to the student’s safety but this isn’t true. A school dress plays an important role in the safety of a pupil. For instance, let’s think there’s an intruder in the school. He/she will be instantly recognized as he/she will not be in the specific dress code. Since there are appearance benchmarks set up for a school uniform arrangement, instructors and chairmen can rapidly recognize people on grounds who ought not to be available. That can make additional opportunities to start a lockdown of the school property or take other precaution wellbeing estimates which can guard students. In terms of safety, school uniforms also help to stop violence. President Clinton said,“ If it means that teenagers will stop killing each other over designer jackets, then our public schools should be able to require their students to wear school uniforms.”

Other arguments opposers of school uniforms make is that children aren’t able to express themselves due to the uniform norms being set by the school but this isn’t much true. Students can find much more different ways to express themselves other than by wearing their favorite clothes. They can express themselves through their studies, co-curricular activities, sports, etc.

As some people say that uniforms are just a waste of time but in reality, they are a real-time saver. Now, suppose you are a student. There is an exam at your school the next morning and instead of choosing what to wear to school, you could study for the exam in the meantime. So, having a dress code set saves time for other important things to do such as study.

For those who said it has nothing to do with the gang culture, it might be not true. School uniforms may help to stop the formation of gangs inside the school campus. Students of a specific age will quite often oppose something. For the poor individuals, that resistance may concentrate on the individuals who are rich and have more than them. For the individuals who are well off, the defiance may concentrate on ‘uncalled for’ school arrangements, school costs, or other budgetary weights that may not have any significant bearing on different students. Since outfits put the attention on equity rather than disparity, these approaches work to forestall a portion of the normal reasons why students target each other or the school region.

Some people disagree with the fact that dress codes promote social values but wearing the same uniform teaches students to behave friendly and helps in the development of good social and conversation skills. Moreover, when they are wearing similar uniforms they feel well connected & learn to pay more attention to other person’s personality and not to their clothes.

Therefore, Wearing a school uniform makes youngsters glad to be a piece of their school since it controls distance, structures class/school solidarity, and separates between the understudies and instructors. It gives youngsters the structure they need, while not expelling any inventiveness from them. It also helps in saving time, is less expensive, promotes equality, and promotes the safety of children. Hence, I fully agree with the fact that uniforms should be compulsory in schools.  

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Persuasive Essay About School Uniforms

Table of contents:

• Introduction
• Body paragraphs

Should students wear school uniforms? This is a topic with a lot of controversy around it. Some people think it should be compulsory to wear a uniform, and others think they should not be required. Your persuasive essay should take a strong stand on the issue, but don’t fail to consider the arguments against your point of view as well as the benefits of your own beliefs.

Your introduction should consist, most importantly, of your thesis or focus statement, in which you answer the question, “Why should we wear (or not wear) school uniforms?” When considering the pros and cons, make up your mind first which stance you’d like to argue for, and then reflect on how best to make your point.

Introduction examples

Pro: School uniforms ensure that all students have the same access to well-fitting, modest clothing during classes, and also erase the differences between richer and poorer students, putting them all on a more equal footing.

Con: School uniforms are restrictive of personal expression, uncomfortable, and needlessly force children into gender roles due to making girls wear skirts and boys wear trousers, and so they should not be required.

The body of your essay should then expand upon the thesis, outlining and backing up each of your points. If you have statistics to back up your arguments, here’s where to use them. You can also use anecdotes, common sense appeals, or appeals to emotion.

Body paragraphs examples

Pro: School uniforms should be compulsory. They reduce time spent shopping, as well as money spent buying clothes, and eliminate bullying based on dress and appearance. In addition, they keep students safer by making sure they are obviously dressed as students.

Con: There are many reasons against wearing school uniforms. No one, first of all, likes to be forced into a particular mould. The subject of whether school uniforms actually prevent bullying is still up for debate. As well, one of the disadvantages is that school uniforms usually have to all be bought from the same place, which can lead to collusion between school governors and clothing shops.

As you draw to a conclusion, look back at your thesis. Give your essay a title that relates to the thesis. Make sure you’ve covered all the points you want to cover. Then go over those points again in your conclusion, and finally end with a request to your audience to take some kind of action, or at least consider the debate from a different point of view.

Conclusion examples

Pro: To have more peaceful, safer schools, as well as cheaper shopping bills, uniforms are the way to go. It’s the better option for students, and it’s better for parents as well, so recommend to your school board that uniforms should be instituted right away.

Con: The jury’s still out on whether school uniforms do make a difference. In the meantime, why curb kids’ personal expression? Let them dress the way they want, within reason. It doesn’t cause them any harm.

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All Children Should be Made to Wear School Uniforms- IELTS Writing Task 2

Updated On Feb 09, 2024

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All children should be made to wear school uniforms. To what extent do you agree or disagree?

Opinion Essay

Introduction

Sentences 1&2 – Mention that this topic has both aspects to discuss using synonyms to create a basic understanding.

Sentence 3 – Mention your stand on the topic.

Body paragraphs

Paragraph 1 – Talk about why uniforms are essential in schools.

Paragraph 2 – Mention that the uniform enables children to concentrate more on studies rather than on their wardrobe.

Paragraph 3 – Acknowledge the flip side of the argument.

Restate your views.

Sample Essay

Many schools make it requisite for their students to wear a uniform, but recently, this policy has been criticised as oppressive. I fundamentally believe that uniforms are an obligatory component of school life and should be maintained for practical and pedagogical reasons.

There are many reasons why uniforms are essential in schools. To start with, it creates a positive environment in schools; consequently, school decorum is maintained efficiently as poor children are not bullied based on their clothes. It also eradicates any disparity between the rich and poor pupils. Consequently, a happy environment is concocted.

Moreover, the uniform enables children to concentrate more on their studies rather than on their wardrobe. When they do not have to worry about what to wear to school, they can work to achieve their goals. Additionally, parents’ hard-earned money is saved as children are supposed to abide by uniforms. For instance, many parents are happy to send their children to schools where uniforms are compulsory.

On the other hand, some high schools do not entail their students to wear uniforms. Uniforms should not be the primary concern of academic education, and schools should focus more on the curriculum quality and learning process than on attire. Furthermore, spending on school uniforms can be an unthrifty investment, as the fund could be administered for books or stationery.

To conclude, I would pen down to say that wearing a school uniform for students is vital for the quality of the studying process. Still, school children should also have the opportunity to not wear a school uniform because of factors like price and financial options in families.

Meaning – made necessary by particular circumstances or regulations. Example – The application will not be processed until the requisite fee is paid.

Meaning – required by a legal, moral, or other rule; compulsory. Example – Use of seat belts in cars is now obligatory.

• Pedagogical

Meaning – relating to teaching. Example – Some professors in the college are adopting innovative pedagogical methods.

Meaning – destroy completely; put an end to. Example – Polio has been eradicated from India.

Meaning – create or devise (a story or plan). Example – Ana’s friends concocted a simple plan to fool her.

Meaning – accept or act in accordance with (a rule, decision, or recommendation). Example – I know Asha will abide by their decision.

Meaning – involve (something) as a necessary or inevitable part or consequence. Example – When such a situation is aroused, it entails considerable risks.

Meaning – clothes, especially fine or formal ones. Example – There is a type of attire set by the Bar Council for their advocates.

Meaning – not using money and other resources carefully; wasteful. Example – If Ricky continues to waste his property in an unthrifty way, he will soon be bankrupt.

Meaning – absolutely necessary; essential. Example – Maintaining secrecy is of vital importance in the FBI investigation.

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School Uniforms Essay | Short and Long Essays, Importance and Benefits of School Uniforms

School Uniforms Essay: School uniforms should be utilized in educational systems. Uniforms are both as useful for schools just as for the pupils. Wearing outfits will help construct a feeling of solidarity inside the school. Rather than everybody as a different group, everybody will be in a similar group. Wearing regalia will help free pupils of the pressure of what to wear in the first part of the day. Wearing school outfits will help improve understudy distinction and improve their confidence. To start with, wearing coordinating outfits can cause pupils to feel equivalent. Helpless pupils would at this point don’t feel rejected on the grounds that they are not wearing name-brand garments like the more extravagant children.

You can read more  Essay Writing  about articles, events, people, sports, technology many more.

What is a School Uniform?

In straightforward words, we comprehend that the Uniform or material which is recommended by the school for pupils to wear in school is called school uniform. Generally in all schools uniform is mandatory.The Uniform gives balance and comparability between the pupils, everything being equal. These days, all schools keep the principles of wearing a normalized uniform for all pupils.

How to Write a School Uniform Essay?

To write an essay students should know the proper format. Also, they should be well aware of the topic on which they have to write the essay. Writing an essay on school uniforms requires the knowledge of the merits and demerits of wearing a school uniform. Students should list down the advantages of uniforms in schools.

Remember these points while writing the essay on school uniform:

• Give introduction on school uniform in the first paragraph
• Explain the advantages and disadvantages of wearing a school uniform
• Explain how wearing a uniform brings changes in students
• Conclude the essay in the last paragraph

Short Essay on School Uniform 150 Words in English

School uniforms are the solitary most apparent fundamental components of any school. We can distinguish the understudy by assessing their regalia.

It is said that, in the sixteenth century, Christ’s Hospital School originally utilized the school uniform. There has been a discussion everywhere in the world on whether the subject of school uniforms is positive or negative. Common liberties activists say that school uniforms are removing their opportunity of wearing anything. In guard, the School Committee says they give a school uniform to instruct them in order and solidarity.

School uniforms can build the pay of a custom-fitted local area. And furthermore, a business organization can bring in cash by creating school regalia. School uniforms are a conventional clothing standard including a shirt and full gasp for young men and pullovers and creased skirts for young ladies. School dress can lessen fabric harassment.

Yet in addition, these days youngsters are more cognizant about their design sense and sexual direction, so they don’t prefer to wear a similar unisex clothing standard. However, after every one of those contentions and dubious speculations, we can say, school regalia are as a matter of fact pride for an understudy.

Long Essay on School Uniform 650 Words

Schools are instructive establishments where kids go not exclusively to learn course readings however to develop as a general person. Schools likewise have the assignment of showing youngsters the desire for garments and mention to them what is proper for what event. School outfits are a basic type of garments for pupils during their visit at school during school hours, and outside during true school exercises. A school uniform is normal in a large portion of the schools. They have direct requests to wear the school uniform as a matter of course.

The necessity of School Uniform

Initially, school is where we all progress at an extremely youthful age. In a single word, life starts at school. It’s schooling, as well as school, gives us the stage to sustain our confidence, feelings in the beginning phase of life. The significance of making companions, functioning as a group we get familiar with every one of these in school. What’s more, wearing a similar dress unquestionably brings a feeling of solidarity among pupils. In each school, there are pupils from various foundations yet with the school uniform everybody becomes one-the lone character rules at that point is every one of them is the delegate of a similar school. This is an incredible inclination of harmony. This likewise assists kids with defeating the inadequacy (or predominance) complex which here and their kids have due to the climate they have been raised in. School outfits streak out a large portion of the drops of social contentions.

As school makes our crucial nuts and bolts of the future it is critical to cause one to feel as a piece of the school. A youngster with a specific school uniform constantly feels that he has a place with the school. It makes the youngster more cognizant about his distinction which thus helps to build fearlessness. A kid would be more thoughtful to his kindred cohort who has a similar uniform as his. As referenced before there would be consistently a blended group in each school. Some of them are rich, some have a place with the upper working class and some lower than that-this distinction remains all over, aside from those 8 hours in school due to the school uniform. The supposed status cognizance doesn’t exist with this.

Benefits of School Uniform

Another admirable sentiment comes up while examining the benefits of school uniform is younger students go through two most significant progress times of life in school-they burn through 12 long a long time in school-from adolescence to teen, from adolescent to youth-the school observer the progressions ( both physical and mental) happen inside one. During these changes, somebody barely thinks often about the world. That time there is a propensity among us all to disrupt the norm which should be managed cautiously and strategically.

Now wearing school regalia assumes a quiet yet urgent part in our lives. It ingrains a profound established feeling of control in the psyche mind. Subsequently, typically even the riskiest formally dressed understudy wonders whether or not to do any underhandedness outside the school as the moment suspected plays to him that he will let down his school with his activity. School uniform assists an understudy with focusing on his necessities-where school and scholastics start things out.

Even after some elegantly composed diagrams of papers on school uniforms, the contention on whether a school uniform abuses the pupils’ privilege of articulation will stay a ceaseless conversation. Be that as it may, truly, wearing of regalia should all rely upon the conditions and the picture a given school is attempting to depict. In any case, the significance of school uniforms appears to win the day today even as I compose this end and surprisingly after so many school uniform articles have been composed. On the last note, we should attempt to discover perpetual methods of tackling the developing issues looked at by pupils. We ought not to depend on school regalia to swipe the issues away from view, this does the pupils nothing but bad.

Importance of School Uniform

The uniform is a necessary piece of our life. The dress is a character of somebody. Through the dress, we become acquainted with which school the understudy is. The educator has a crucial part in picking a dress. He chooses the school uniform by taking a gander at all the classes. Uniform symbols, alongside schooling, order, and decorum help in altering the state and course of society.

Wearing legitimate clothing expands our trust in the public arena since it positively affects our work and thinking. These days, our local area has gotten a matter of rivalry for our kids. It appears to be that their dress is influencing them every day.

The wearing of our kids has additionally become an essential factor somewhat for the criminal occurrences occurring in the public eye. In an understudy’s life, the educator and parent are the types of God. School dress is viewed as a recipe for equity.

Advantages of School Uniform

• School uniforms are a need in many schools to achieve consistency in pupils.
• School uniform binds together all pupils, paying little heed to their social, strict, and monetary foundation.
• It imparts a feeling of having a place in the pupils.
• It assists with restraining pupils and keeps everything under control since they are not occupied by their special garments.
• pupils don’t have to object about what to wear each day in the event that they have school regalia.
• It is hard for low-pay families to purchase school regalia each spending year, and it might make a strain in their financial plan.
• School outfits force consistency and consequently make pupils a mass of anonymous kids and with no singularity.
• It is hard for pupils to check their friend’s monetary condition in the event that they are wearing school dresses.
• pupils can be not kidding about their examinations and figure out how to endeavor to be deserving of the custom.
• School dress can make pupils unoriginal.

FAQ’s on Schools Uniforms Essay

Question 1. What students should wear uniforms in school?

Answer: Uniforms are both as useful for schools just as for the pupils. Wearing uniforms will help fabricate a feeling of loneliness inside the school. To start with, wearing coordinating uniforms can cause pupils to feel equivalent. Helpless pupils would presently don’t feel barred in light of the fact that they are not wearing name-brand garments like the more extravagant children.

Question 2. How to write an essay on a school uniform?

Answer: Start with an introduction, discuss the debate going on school uniforms by students, write the cons and pros of school uniforms. Explains the advantages and changes that wearing a school uniform can bring in students. End the essay with a conclusion.

Question 3. What is good about school uniforms?

Answer: School uniforms have been demonstrated to raise test scores, support confidence, diminish savagery and wrongdoing, and make a feeling of freshly discovered pride in pupils. They assist youngsters with zeroing in on learning and homework, not on the thing every other person is wearing or whether they fit in. Outfits are not the answer for the entirety of the issues that adolescents, instructors, and schools face today, however, examination and insights propose that they might be a positive development.

Question 4. Should students wear school uniforms?

Answer: Yes, all students should wear school uniforms since it represents discipline and equality among students in school.

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initiative petition. We received initial briefs from the Attorney General and four other opponents of the proposed amendment: Susan B. Anthony Pro Life America ("Susan B. Anthony"); the National Center for Life and Liberty ("Center for Life"); Florida Voters Against Extremism; and the Florida Conference of Catholic Bishops. We received answer briefs arguing in favor of placing the proposed amendment on the ballot from the Sponsor and four other proponents: certain Former Florida Republican Elected Officials ("Former Republican Officials"); the American College of Obstetricians and Gynecologists; certain Florida Doctors; and certain Law Professors and Instructors. Oral argument was heard on February 7, 2024. The full text of the proposed amendment, which would create a new section in the Declaration of Rights in article I of the Florida Constitution, states: SECTION . Limiting government interference with abortion. Except as provided in Article X, Section 22, no law shall prohibit, penalize, delay, or restrict abortion before viability or when necessary to protect the patient's health, as determined by the patient's healthcare provider. ▬ - 2

The ballot title for the proposed amendment is "Amendment to Limit Government Interference with Abortion,” and the ballot summary states: No law shall prohibit, penalize, delay, or restrict abortion before viability or when necessary to protect the patient's health, as determined by the patient's healthcare provider. This amendment does not change the Legislature's constitutional authority to require notification to a parent or guardian before a minor has an abortion. II. ANALYSIS A. Standard of Review In reviewing the validity of an initiative petition for placement on the ballot, "[t]his Court has traditionally applied a deferential standard of review." Advisory Op. to Att'y Gen. re Use of Marijuana for Certain Med. Conditions (Medical Marijuana I), 132 So. 3d 786, 794 (Fla. 2014). Without regard to the merits or wisdom of the initiative, our review is limited to the following issues: (1) "the compliance of the text of the proposed amendment or revision with s. 3, Art. XI of the State Constitution"; (2) "the compliance of the proposed ballot title and substance with s. 101.161"; and (3) "whether the proposed amendment is facially invalid under the United States Constitution." § 16.061(1), Fla. Stat (2023). This - 3

Court will invalidate a proposed amendment "only if it is shown to be 'clearly and conclusively defective." "1 Advisory Op. to Att'y Gen. re Regulate Marijuana in a Manner Similar to Alcohol to Establish Age, Licensing, & Other Restrictions, 320 So. 3d 657, 667 (Fla. 2021) (quoting Advisory Op. to Att'y Gen. re Amend. to Bar Gov't from Treating People Differently Based on Race in Pub. Educ. (Treating People Differently), 778 So. 2d 888, 891 (Fla. 2000)). This Court's review of a proposal's compliance with article X, section 3 and section 101.161 is governed by the following principles: First, the Court will not address the merits or wisdom of the proposed amendment. Second, "[t]he Court must act with extreme care, caution, and restraint before it removes a constitutional amendment from the vote of the people." Specifically, where citizen initiatives are concerned, “[the] Court has no authority to inject itself in 1. In her briefing, the Attorney General invites this Court to reconsider its long-held requirement that to invalidate a ballot initiative, this Court must conclude that the initiative is clearly and conclusively defective. The Attorney General suggests that this Court need only consider whether the initiative violates the requirements of section 101.161(1), not whether it does so "clearly." Essentially, the Attorney General seeks to reduce the opponents' burden here, see Floridians Against Casino Takeover v. Let's Help Florida, 363 So. 2d 337, 339 (Fla. 1978) (stating that the burden upon the opponent of an initiative proposal is to establish that the proposal is "clearly and conclusively defective" (quoting Weber v. Smathers, 338 So. 2d 819 (Fla. 1976); Goldner v. Adams, 167 So. 2d 575 (Fla. 1964))), which we decline to do. - 4 -

the process, unless the laws governing the process have been 'clearly and conclusively' violated." Advisory Op. to Att'y Gen. re 1.35% Prop. Tax Cap, Unless Voter Approved, 2 So. 3d 968, 971 (Fla. 2009) (alterations in original) (citations omitted). With these principles in mind, we turn to the task at hand. B. Single-subject Requirement Article XI, section 3 of the Florida Constitution provides in pertinent part: The power to propose the revision or amendment of any portion or portions of this constitution by initiative is reserved to the people, provided that, any such revision or amendment, except for those limiting the power of government to raise revenue, shall embrace but one subject and matter directly connected therewith. (Emphasis added.) “[I]n determining whether a proposal addresses a single subject the test is whether it ‘may be logically viewed as having a natural relation and connection as component parts or aspects of a single dominant plan or scheme."" Fine v. Firestone, 448 So. 2d 984, 990 (Fla. 1984) (quoting City of Coral Gables v. Gray, 19 So. 2d 318, 320 (Fla. 1944)). In other words, a proposal must manifest "a logical and natural oneness of purpose" to -5

accomplish the purpose of article XI, section 3.2 Advisory Op. to Att'y Gen. re Fla. Marriage Prot. Amend. (Marriage Protection), 926 So. 2d 1229, 1233 (Fla. 2006) (quoting Fine, 448 So. 2d at 990). The single-subject requirement is intended to "prevent[] a proposal ‘from engaging in either of two practices: (a) logrolling; or (b) substantially altering or performing the functions of multiple branches of state government.'" Medical Marijuana I, 132 So. 3d at 795 (quoting Advisory Op. to Att’y Gen. re Water & Land Conservation-Dedicates Funds to Acquire & Restore Fla. Conservation & Recreation Lands (Water & Land Conservation), 123 2. Opponent Susan B. Anthony urges this Court to reconsider the "oneness of purpose" standard, asserting that it is too subjective and that the plain text of article XI, section 3, requiring “one subject," should instead be read more narrowly as requiring "one proposition." While Susan B. Anthony suggests that a narrower interpretation of the single-subject requirement would be more faithful to the supremacy-of-text principle, its interpretation bears little relationship to the actual constitutional text. There is a difference between a proposal addressing a particular “subject," and one that presents a single "proposition," and the constitutional text plainly states that an initiative "embrace but one subject." Further, Susan B. Anthony ignores the text that immediately follows the word "subject" in article XI, section 3, which plainly permits a proposed amendment to address "matter directly connected" to the single subject. Finally, our cases do not reflect a commitment to defining “subject” in such a narrow manner. We thus decline Susan B. Anthony's invitation to adopt a narrower interpretation of the single-subject requirement. -6

So. 3d 47, 50-51 (Fla. 2013)). It "is a rule of restraint designed to insulate Florida's organic law from precipitous and cataclysmic change." Advisory Op. to Att'y Gen.-Save Our Everglades (Save Our Everglades), 636 So. 2d 1336, 1339 (Fla. 1994). As explained below, the proposed amendment here does not violate the singlesubject requirement. This Court has defined logrolling as “a practice wherein several separate issues are rolled into a single initiative in order to aggregate votes or secure approval of an otherwise unpopular issue." Id. at 1339. "The purpose of the single-subject requirement is to allow the citizens to vote on singular changes in our government that are identified in the proposal and to avoid voters having to accept part of a proposal which they oppose in order to obtain a change which they support." Fine, 448 So. 2d at 993. Susan B. Anthony and Florida Voters Against Extremism assert that the proposed amendment engages in logrolling by reaching two separate categories of abortion-abortion before viability of the fetus and abortion based on a healthcare provider's authority which present distinct moral and policy issues. The "viability provision" would ban any law prohibiting, penalizing, -7

delaying, or restricting abortion before viability, regardless of the circumstances or the mother's reasons for seeking an abortion. This, according to these opponents, would be, in effect, a constitutional guarantee of abortion at any time and for any purpose before the fetus is viable. The “health provision” would bar any law that prohibits, penalizes, delays, or restricts abortion at any time—including after viability and until the moment of birth— so long as a "healthcare provider” says it is necessary to "protect" the mother’s “health”—not “life.” Opponents argue that these two provisions of the proposed amendment involve entirely different subjects. Susan B. Anthony points out that many voters would simultaneously oppose an amendment that prohibits government interference with all previability abortions but support an amendment prohibiting government interference with abortions sought to protect the health of the mother. Opponents argue that the proposed amendment forces those voters "to accept part of a proposal which they oppose," id.-a ban on laws prohibiting abortion before viability—“in order to obtain a change which they support," id.-a ban on laws prohibiting abortion when maternal health is in need of protection. The Sponsor and other proponents -8

contend that the proposed amendment addresses a single subject, namely, "limiting government interference with abortion." Under both Florida and federal law, the subject of abortion has historically involved two major interconnected matters: the viability of the fetus and the health of the mother. See generally Dobbs v. Jackson Women's Health Org., 597 U.S. 215, 301 (2022); Roe v. Wade, 410 U.S. 113, 163-64 (1973), overruled by Dobbs, 597 U.S. 215, and holding modified by Planned Parenthood of Se. Pa. v. Casey, 505 U.S. 833 (1992); In re T. W., 551 So. 2d 1186, 1190 (Fla. 1989), receded from by Planned Parenthood of Sw. & Cent. Fla. v. State, No. SC2022-1050 (Apr. 1, 2024) (slip op. at 2). “Abortion"or, more specifically, “limits on government interference with abortion"—is the subject of the proposed amendment, and the viability of the fetus and the mother's health are “matter[s] directly connected” thereto. For this reason, the argument that the proposed amendment violates the single-subject requirement because voters may support some of the amendment's applications but not others also fails. Whether some voters may support only a portion of a proposed amendment and oppose another portion is not the inquiry that determines whether there is a violation of the - 9

single-subject requirement. Instead, the prohibition on "logrolling refers to a practice whereby an amendment is proposed which contains unrelated provisions, some of which electors might wish to support, in order to get an otherwise disfavored provision passed." Advisory Op. to Att'y Gen. re Rts. of Elec. Consumers Regarding Solar Energy Choice (Solar Energy Choice), 188 So. 3d 822, 828-29 (Fla. 2016) (emphasis added) (citing Advisory Op. to Att'y Gen. re Protect People, Especially Youth, from Addiction, Disease, & Other Health Hazards of Using Tobacco, 926 So. 2d 1186, 1191 (Fla. 2006)); see also Advisory Op. to Att'y Gen. Ltd. Marine Net Fishing, 620 So. 2d 997, 999 (Fla. 1993) (“The purpose of the single-subject restriction is to prevent the proposal of an amendment which contains two unrelated provisions, one which electors might wish to support and one which they might disfavor." (emphasis added)). Because viability and maternal health are interconnected matters related to the subject of abortion, the mere fact that electors might not agree with the entirety of the amendment does not render it violative of the single-subject requirement. The Former Republican Officials point out that this Court has repeatedly approved ballot measures that addressed multiple - 10 -

related facets of a subject. For example, in Marriage Protection, the proposed amendment both defined "marriage" as "the legal union of only one man and one woman” and prohibited “the substantial equivalent thereof,” i.e., civil unions or domestic partnerships. 926 So. 2d at 1232. Although the opponents of the proposed amendment in that case contended that the definition of "marriage" and the prohibition on substantial equivalents were separate subjects, this Court concluded that they were both facets of “the singular subject of whether the concept of marriage and the rights and obligations traditionally embodied therein should be limited to the union of one man and one woman." Id. at 1234. Similarly, within the context of the proposed amendment here, abortion "before viability" and "when necessary to protect the patient's health" are not separate subjects but facets of the singular subject of whether government "interference with abortion" should be "limit[ed]" when those circumstances are present. We have explained that "a proposed amendment may 'delineate a number of guidelines' consistent with the single-subject requirement as long as these components possess ‘a natural relation and connection as component parts or aspects of a single dominant plan or scheme.' - 11 - 99

Medical Marijuana I, 132 So. 3d at 796 (quoting Advisory Op. to Att'y Gen. re Standards for Establishing Legis. Dist. Boundaries, 2 So. 3d 175, 181-82 (Fla. 2009)). Banning laws that restrict previability abortion and abortion performed to protect maternal health are aspects of a single scheme: limiting government interference with abortion. Susan B. Anthony's reliance on In re Advisory Opinion to the Attorney General—Restricts Laws Related to Discrimination (Discrimination Laws), 632 So. 2d 1018 (Fla. 1994), in support of its position is misplaced. The proposed amendment in that case stated, in pertinent part, The state, political subdivisions of the state, municipalities or any other governmental entity shall not enact or adopt any law regarding discrimination against persons which creates, establishes or recognizes any right, privilege or protection for any person based upon any characteristic, trait, status, or condition other than race, color, religion, sex, national origin, age, handicap, ethnic background, marital status, or familial status. Id. at 1020. This Court concluded that the proposed initiative violated the single-subject rule because “it enumerate[d] ten classifications of people that would be entitled to protection from discrimination if the amendment were passed.” Id. (“[A] voter may - 12 -

want to support protection from discrimination for people based on race and religion, but oppose protection based on marital status and familial status."). Here, unlike what we characterized as the “expansive generality” and “disparate" classifications present in Discrimination Laws, the proposed amendment concerns only a single item—abortion. Susan B. Anthony also relies on Advisory Opinion to the Attorney General re Fairness Initiative Requiring Legislative Determination that Sales Tax Exemptions and Exclusions Serve a Public Purpose (Fairness Initiative), 880 So. 2d 630 (Fla. 2004). In that case, we concluded that the proposed amendment contain[ed] three disparate subjects: (1) a scheme for the Legislature to review existing exemptions to the sales tax under chapter 212; (2) the creation of a sales tax on services that currently does not exist; and (3) limitations on the Legislature's ability to create or continue exemptions and exclusions from the sales tax. Id. at 634. This Court reasoned that [w]hile all of these three goals arguably relate to sales taxes, and any one of these three goals might be the permissible subject of a constitutional amendment under the initiative process, we conclude that together they constitute impermissible logrolling and violate the singlesubject requirement of article XI, section 3, of the Florida Constitution because of the substantial, yet disparate, impact they may have. - 13 -

Id. at 635. The elements of the proposed amendment in Fairness Initiative lacked the “natural relation and connection" present in the proposed amendment in this case. The singular goal of the proposed amendment here is to limit government interference with the termination of pregnancy. It involves one subject and addresses the related ability of State and local governments to “interfere[] with" that subject. The proposed amendment also will not substantially alter or perform the functions of multiple branches of government. "This Court has held that while most amendments will 'affect' multiple branches of government this fact alone is insufficient to invalidate an amendment on single-subject grounds . . . ." Advisory Op. to Att'y Gen. re Right to Treatment & Rehab., 818 So. 2d 491, 496 (Fla. 2002). Indeed “it [is] difficult to conceive of a constitutional amendment that would not affect other aspects of government to some extent." Solar Energy Choice, 188 So. 3d at 830 (alteration in original) (quoting Advisory Op. to Att'y Gen. re Ltd. Casinos, 644 So. 2d 71, 74 (Fla. 1994)). But it is only "when a proposal substantially alters or performs the functions of multiple branches that it violates the single-subject test.'" Medical Marijuana I, 132 So. 3d at 795 - 14 -

(emphasis added) (quoting Advisory Op. to Att'y Gen. re Fish & Wildlife Conservation Comm'n, 705 So. 2d 1351, 1353-54 (Fla. 1998)); see also Advisory Op. to Att'y Gen. re Prohibiting State Spending for Experimentation that Involves the Destruction of a Live Hum. Embryo (Prohibiting State Spending), 959 So. 2d 210, 213 (Fla. 2007) ("While we recognize that the proposed amendment, if enacted, appears to limit the authority of the legislative and executive branches of state government, we conclude that this proposed amendment does not substantially alter or perform the functions of multiple branches of government."). Here, the proposed amendment will affect the government "only in the general sense that any constitutional provision does" by requiring compliance with a new constitutional rule. Solar Energy Choice, 188 So. 3d at 830. It will not require any of the branches of government to perform any specific functions nor would it substantially alter their functions. Instead, it primarily restricts the authority of the legislative branch to pass legislation that would “interfere” with abortion under certain circumstances. This is not the type of “precipitous” or “cataclysmic” change to the government structure indicative of substantially altering or performing the - 15 -

functions of multiple branches of government that the singlesubject rule is intended to prevent. See, e.g., In re Advisory Op. to Att'y Gen. re Limits or Prevents Barriers to Local Solar Elec. Supply, 177 So. 3d 235, 244-45 (Fla. 2015) (concluding that although the proposed amendment would limit the authority of the Legislature and other governmental entities to regulate in certain areas, it did "not substantially alter or perform the functions of multiple branches of government producing ‘precipitous' or ‘cataclysmic' changes"). We conclude that the proposed amendment before us embraces but one subject-limiting government interference with abortion and matter directly connected therewith. It does not violate the single-subject provision of article XI, section 3. C. Ballot Title and Summary Section 101.161(1), Florida Statutes (2023), sets forth certain technical and clarity requirements for ballot titles and summaries. As to the technical requirements, the statute requires that the ballot title "consist of a caption, not exceeding 15 words in length, by which the measure is commonly referred to or spoken of" and that "[t]he ballot summary of the amendment or other public - 16

measure shall be an explanatory statement, not exceeding 75 words in length, of the chief purpose of the measure." § 101.161(1), Fla. Stat. Here, the ballot title is composed of seven words and the ballot summary is composed of thirty-four words, clearly meeting the word count limitations provided in section 101.161(1). Section 101.161(1) also requires that a ballot summary “be printed in clear and unambiguous language.” “This is to provide fair notice of the content of the proposed amendment so that the voter will not be misled as to its purpose, and can cast an intelligent and informed ballot." Advisory Op. to Att'y Gen.-Fee on Everglades Sugar Prod., 681 So. 2d 1124, 1127 (Fla. 1996). "Accordingly, in reviewing the ballot title and summary, this Court asks two questions: (1) whether the ballot title and summary fairly inform the voter of the chief purpose of the amendment; and (2) whether the language of the ballot title and summary misleads the public." Solar Energy Choice, 188 So. 3d at 831. "[I]t is not necessary to explain every ramification of a proposed amendment, only the chief purpose." Water & Land Conservation, 123 So. 3d at 50-51 (alteration in original) (quoting Advisory Op. to Att’y Gen. re - 17 -

Additional Homestead Tax Exemption (Homestead Tax Exemption), 880 So. 2d 646, 651 (Fla. 2004)). Opponents contend that the ballot title and summary fail to fairly inform voters of the chief purpose of the amendment because, they argue, the chief purpose is not to limit government interference with abortion, as the title states, but to effectively provide for abortion on demand, up until the moment of birth, by requiring broad exceptions for maternal health. The opponents find it all but impossible to imagine a circumstance in which a woman who wants a postviability (including late-term or partial-birth) abortion will not be able to find a “healthcare provider” willing to say that an abortion is somehow necessary to protect her health-physical, mental, or otherwise. The opponents further argue that the ballot title and summary do not fully inform voters that the sweep of the proposed amendment is broad in its collateral effects on current Florida statutes regulating abortion; that the amendment may authorize late-term abortions for the sake of maternal health; or that “health” could encompass mental as well as physical health. While it may well be true that the proposed amendment would have broad effects flowing from its adoption that are not fully - 18 -

explained in the ballot summary, to fairly inform voters of its chief purpose, a ballot summary—as we have already said-“need not explain every detail or ramification of the proposed amendment." Treating People Differently, 778 So. 2d at 899 (quoting Advisory Op. to Att'y Gen. re Prohibiting Pub. Funding of Pol. Candidates, 693 So. 2d 972, 975 (Fla. 1997)). Nor must it provide “an exhaustive explanation of the interpretation and future possible effects of the amendment." Id. The ballot summary here tracks the language of the proposed amendment itself and provides that “no law shall prohibit, penalize, delay, or restrict abortion before viability or when necessary to protect the patient's health, as determined by the patient's healthcare provider.” That the proposed amendment’s principal goal and chief purpose is to limit government interference with abortion is plainly stated in terms that clearly and unambiguously reflect the text of the proposed amendment. And the broad sweep of this proposed amendment is obvious in the language of the summary. Denying this requires a flight from reality. We acknowledge that the text of the amendment—like any legal textpresents interpretive questions, but we neither endorse nor reject - 19 -

any litigant's assertions about how the proposed amendment might be interpreted in the future and our decision today takes no position on the scope of legislative discretion that would remain if the proposed amendment were to become law. The second question we must consider in reviewing the ballot title and summary is whether the language of the ballot title and summary will be misleading to voters. Medical Marijuana I, 132 So. 3d at 797. The ballot title—“Amendment to Limit Government Interference with Abortion"-clearly identifies the subject of the proposed amendment. Nonetheless, some opponents still contend that the ballot title is misleading because, they suggest, the proposed amendment does more than “limit” government interference with abortion and the phrase "government interference with abortion" is improper inflammatory political rhetoric. We disagree. The word "limit" is not misleading in the title or summary. The proposed amendment does not eliminate the government's ability to "interfere" with abortion in all circumstances; by its plain language, it limits government interference before viability or when necessary to protect the mother's health. Its reference to article X, section 22 of the Florida - 20 -

Constitution which grants the Legislature authority to require notification to a parent or guardian of a minor before termination of the minor's pregnancy-explicitly provides for an instance in which the legislative authority to "interfere[] with" abortion will be preserved in the event the proposed amendment is passed. And the proposed amendment would not prohibit the Legislature from passing laws "“interfering” with abortion after the point of viability and when the mother's health is not in jeopardy. The ballot title's inclusion of the word "limit" is therefore not misleading but accurately explains that the Legislature will retain authority to “interfere[] with” abortions under certain circumstances. Nor does the ballot title contain inflammatory political rhetoric. The "government interference" language in the ballot title is also found in both state and federal abortion precedent. See, e.g., N. Fla. Women's Health & Counseling Servs., Inc. v. State, 866 So. 2d 612, 615 (Fla. 2003) ("Under our decision, parent and minor are free to do as they wish in this regard, without government interference.”), receded from by Planned Parenthood of Sw. & Cent. Fla., No. SC2022-1050 (Apr. 1, 2024) (slip op. at 2-3, 50); Dobbs, 597 U.S. at 273 (reasoning that Roe conflated “the right to shield - 21

information from disclosure and the right to make and implement important personal decisions without governmental interference"). The "government interference" terminology is a fair description of the proposal. Thus, we cannot say that the phrase "government interference” is inflammatory political rhetoric. The opponents contend that the ballot summary is misleading because it fails to define “viability,” “health,” or “healthcare provider"; does not disclose that it might be left to a “healthcare provider” to determine when a fetus is viable; and does not disclose that despite its proclamation that no law will prohibit previability abortion, previability partial-birth abortions will remain prohibited under the federal partial-birth abortion ban, see 18 U.S.C. § 1531. But none of these things render the summary misleading or inadequate in any way. This Court has held that it will not strike a proposal from the ballot based upon an argument concerning "the ambiguous legal effect of the amendment's text rather than the clarity of the ballot title and summary." Advisory Op. to Att'y Gen. re Voter Control of Gambling (Voter Control of Gambling), 215 So. 3d 1209, 1216 (Fla. 2017). The question for our consideration here is not whether the - 22 -

proposed constitutional language itself is free of any ambiguity or whether there are uncertainties regarding the potential legal effect if the proposed amendment were to pass but whether the ballot summary misleads voters as to the new constitutional language voters are asked to adopt in the proposed amendment itself. In other words, it asks whether the ballot summary will give voters a false impression about what is contained in the actual text of the proposed amendment. The ballot summary essentially follows the language of the proposed amendment. It says nothing more and nothing less than what the operative language of the proposed amendment itself says. In light of this almost verbatim recitation of the text of the proposed amendment, it cannot be said that the ballot summary will mislead voters regarding the actual text of the proposed amendment. See Advisory Op. to Att'y Gen. re Voting Restoration Amend., 215 So. 3d 1202, 1208 (Fla. 2017) (“[T]he ballot title and summary also do not mislead voters with regard to the actual content of the proposed amendment. Rather, together they recite the language of the amendment almost in full."); Prohibiting State Spending, 959 So. 2d at 214 (upholding a summary that contained language identical to - 23 -

that in the proposed amendment); Marriage Protection, 926 So. 2d 1229 (upholding a summary that reiterated almost all of the language contained in the amendment); Advisory Op. to Att'y Gen. re Med. Liab. Claimant's Comp. Amend., 880 So. 2d 675 (Fla. 2004) (same). The fundamental problem with the main clarity arguments advanced by the opponents is that they effectively would impose requirements on the substance of a proposed amendment rather than require accuracy in the ballot summary. But an alleged ambiguity of a proposed amendment itself does not render a ballot summary misleading. And this Court "does not have the authority or responsibility to rule on the merits or the wisdom of these proposed initiative amendments." Treating People Differently, 778 So. 2d at 891 (quoting Advisory Op. to Att'y Gen. re Tax Limitation, 644 So. 2d 486, 489 (Fla. 1994)). There is simply no basis in the constitution for imposing a requirement for clarity on the substance of a proposed amendment. And section 101.161(1)'s requirement for a ballot summary to be in “clear and unambiguous language" cannot be reasonably understood as imposing an extraconstitutional requirement concerning the substance of proposed - 24 -

amendments. Nor should a summary be expected to resolve every interpretive question presented by a proposed amendment. Any summary that attempts to do so will no doubt be challenged for making the wrong interpretive choices. Indeed, the sponsor of an initiative does not have the authority-under the guise of clarification to use the ballot summary to narrow or broaden the meaning of the words used in the amendment text itself. In our legal system, the meaning of terms placed in the constitution is determined by the application of established interpretive conventions and separation of powers principles; legal meaning is not dictated by an amendment's sponsor. The opponents argue that the proposed amendment is misleading for failing to mention that it would not affect the federal ban on partial-birth abortion. "This Court has . . . never required that a ballot summary inform voters as to the current state of federal law and the impact of a proposed state constitutional amendment on federal statutory law as it exists at this moment in time." Medical Marijuana I, 132 So. 3d at 808. This case is thus distinguishable from Advisory Opinion to the Attorney General re Adult Use of Marijuana, 315 So. 3d 1176 (Fla. 2021), in which this - 25 -

Court concluded that a ballot summary was affirmatively misleading "regarding the interplay between the proposed amendment and federal law." Id. at 1180 (quoting Medical Marijuana I, 132 So. 3d at 808). There, we expressly rejected the idea that the ballot summary was defective for failing to "include language that [wa]s not in the proposed amendment itself,” and instead concluded that the ballot summary was defective for its omission of "important language that [wa]s found in the proposed amendment itself.'” Id. at 1183 (quoting Medical Marijuana I, 132 So. 3d at 808). In the end, the ballot title and summary fairly inform voters, in clear and unambiguous language, of the chief purpose of the amendment and they are not misleading. The ballot summary's nearly verbatim recitation of the proposed amendment language is an "accurate, objective, and neutral summary of the proposed amendment." See Homestead Tax Exemption, 880 So. 2d at 653-54 ("[A]n accurate, objective, and neutral summary of the proposed amendment is the sine qua non of the citizen-driven process of amending our constitution.”). Accordingly, there is no basis to - 26

reject the proposed summary and ballot title under section 101.161, Florida Statutes. In reaching this conclusion, we recognize that "the polestar of our analysis is the candor and accuracy with which the ballot language informs the voters of a proposed amendment's effects." Dep't of State v. Fla. Greyhound Ass'n, Inc., 253 So. 3d 513, 520 (Fla. 2018). Here, there is no lack of candor or accuracy: the ballot language plainly informs voters that the material legal effects of the proposed amendment will be that the government will be unable to enact laws that “prohibit, penalize, delay, or restrict" previability abortions or abortions necessary to protect the mother's health. It is undeniable that those are the main and material legal effects of the proposed amendment. "[W]e have also recognized that voters may be presumed to have the ability to reason and draw logical conclusions' from the information they are given." Id. at 520 (quoting Smith v. Am. Airlines, Inc., 606 So. 2d 618, 621 (Fla. 1992)). Because of this, ballot language—as we have previously mentioned—“is not required to explain every detail or ramification of the proposed amendment." Id. (quoting Smith, 606 So. 2d at 620). We thus presume that - 27 -

voters will have an understanding of the obviously broad sweep of this proposed amendment despite the fact that the ballot summary does not and cannot reveal its every possible ramification or collateral effect. Cf. Advisory Op. to Att'y Gen. re Ltd. Casinos, 644 So. 2d at 75 (noting that “[t]he seventy-five word limit placed on the ballot summary as required by statute does not lend itself to an explanation of all of a proposed amendment's details”). Even if elements of ambiguity in the text of a proposed amendment could result in the invalidity of a proposal—a proposition we reject-no such ambiguity has been shown here. Rather, the challenged concepts have been at the forefront of the abortion debate in this country for more than fifty years- -a debate that may be at its height today in the wake of Dobbs. And while some indeterminacy remains regarding these concepts, it is difficult to imagine a Florida voter in 2024 who would be befuddled in any material way by the ballot summary or proposed amendment due to the use of the terms "viability," "health," and "healthcare provider." Regarding whether ambiguity in the text of a proposed amendment can be the basis for a finding that the proposal is invalid, we acknowledge tension in our case law. But we have never - 28 -

given a reasoned explanation of any basis for applying the requirements designed to prevent misleading ballot summaries as a substantive limitation on the content of a proposed amendment. And our most recent pronouncement on the subject is in Department of State v. Hollander, 256 So. 3d 1300, 1311 (Fla. 2018), in which we unequivocally stated: “[T]his Court has held that it will not strike a proposal from the ballot based upon an argument concerning the ambiguous legal effect of the amendment's text rather than the clarity of the ballot title and summary.”” (quoting Voter Control of Gambling, 215 So. 3d at 1216). We see no reason to depart from our most recent ruling on this question. The opponents emphasize our decision in Askew v. Firestone, 421 So. 2d 151 (Fla. 1982). But Askew is entirely inapposite. In Askew, we determined that the chief purpose of the proposed amendment was "to remove the two-year ban on lobbying by former legislators and elected officers." Id. at 156. We found the ballot summary to be fatally defective because although it "indicate [d] that the amendment [wa]s a restriction on one's lobbying activities, the amendment actually g[ave] incumbent office holders, upon filing a financial disclosure statement, a right to immediately commence - 29 -

lobbying before their former agencies which [wa]s . . . precluded." Id. at 155-56. In other words, the ballot summary was fatally misleading because it operated to permit something when it said that it was "[p]rohibit[ing]" something. Id. at 153. No similar infirmity exists in this case. As previously stated, "[t]hat the proposed amendment's principal goal and chief purpose is to limit government interference with abortion is plainly stated in terms that clearly and unambiguously reflect the text of the proposed amendment." Supra at 19. The decision in Wadhams v. Board of County Commissioners of Sarasota County, 567 So. 2d 414 (Fla. 1990), is likewise distinguishable from the circumstances here. In Wadhams, the full text of a charter provision-with amendments engrossed-was placed on the ballot so that the voters were not informed of what was being changed in the text of the charter. Id. at 415. We held "that the chief purpose of the amendment was to curtail the Charter Review Board's right to meet," but nothing on the ballot gave the voter information necessary to understand that fact. Id. at 416. Nothing like that is occurring in this case. - 30

We are told by dissenting colleagues that "the vagueness of the proposed amendment itself leaves many key issues undetermined." Dissenting op. at 46 (Grosshans, J.). Indeed, we are advised that the “language and structure” of the proposed amendment are “overwhelmingly vague and ambiguous” and that the proposal in fact has “no readily discernible meaning.” Dissenting op. at 66 (Sasso, J.). We are further instructed that the summary-in tracking the text of the proposed amendment—“does not attempt to explain that the amendment itself is similarly vague and ambiguous." Id. at 76. Furthermore, the supposed ambiguity is not "self-evident from the vague and ambiguous nature of the summary." Id. We are also told that the language of the summary and proposed amendment “hides the ball” and “explains nothing" but then are instructed on a series of far-reaching "effects" gleaned from that very language. Dissenting op. at 53 (Francis, J.). Again, as we have explained, the suggestion that an amendment sponsor must use a ballot summary to “clarify” the text of an assertedly vague proposal ignores limits on the sponsor's own authority. And we see no basis in law or common sense to require a ballot summary to announce, as if in a warning label, “caution: this - 31

amendment contains terms with contestable meanings or applications." Voters can see and decide for themselves how the specificity of the proposal's terms relates to the proposal's merits. For reasons that are evident from what we have already said, none of this is convincing.3 Lawyers are adept at finding ambiguity. Show me the text and I'll show you the ambiguity. The predominant reasoning in the dissents would set this Court up as the master of the constitution with unfettered discretion to find a proposed amendment ambiguous and then to deprive the people of the right to be the judges of the merits of the proposal. It would open up a playground for motivated reasoning and judicial willfulness. This Court has an 3. It is also suggested that the voters should be informed that the proposed amendment "could, and likely would, impact how personhood is defined for purposes of article I, section 2 of our constitution." Dissenting op. at 49 (Grosshans, J.). The constitutional status of a preborn child under existing article I, section 2 presents complex and unsettled questions. Until our decision today to recede from T.W., this Court's jurisprudence for the past thirty-odd years had assumed that preborn human beings are not constitutional persons. See T.W., 551 So. 2d at 1193-94 (treating the fetus as only "potential life"), receded from on other grounds by Planned Parenthood of Sw. & Cent. Fla., No. SC20221050 (Apr. 1, 2024). Given the unsettled nature of this issue, any "disclosure" would be speculative and therefore unwarranted. - 32 -

important role in determining the validity of proposed amendments and ensuring that ballot summaries do not mislead the voters. But nothing in the law of this state gives the Court a stranglehold on the amendment process. We decline to adopt a standard that would effectively vest us with the power to bar an amendment from the ballot because of a supposed ambiguity in the text of the amendment. We decline to encroach on the prerogative to amend their constitution that the people have reserved to themselves. D. Facial Invalidity In 2020, section 16.061(1), Florida Statutes, was amended to direct the Attorney General that in addition to requesting an advisory opinion regarding the compliance of a proposed amendment and ballot language with article XI, section 3 and section 101.161, she also requests an opinion as to "whether the proposed amendment is facially invalid under the United States Constitution." See ch. 2020-15, § 2, Laws of Fla. Despite this directive, the Attorney General failed to request that we issue an opinion concerning the facial invalidity of the proposed amendment in this proceeding, and only one opponent contends that the proposed amendment is facially invalid. Opponent Center for Life - 33 -

argues that the proposed amendment is facially invalid under the Supremacy Clause of the United States Constitution, because it is preempted by federal law, namely 18 U.S.C. § 1531, which prohibits partial-birth abortion.5 Specifically, the Center for Life argues that the "viability provision" of the proposed amendment-which purportedly would ban any law that “prohibit[s], penalize[s], delay[s], or restrict[s] abortion before viability”—sets up an inherent, irreconcilable conflict with federal law because the proposed amendment's efforts to prohibit any restriction on 4 4. See art. VI, cl. 2, U.S. Const. ("This Constitution, and the Laws of the United States . . . shall be the supreme Law of the Land; and the Judges in every State shall be bound thereby, any Thing in the Constitution or Laws of any State to the Contrary notwithstanding.”). 5. Under federal law, partial-birth abortion is defined as deliberately and intentionally vaginally deliver[ing] a living fetus until, in the case of a head-first presentation, the entire fetal head is outside the body of the mother, or, in the case of breech presentation, any part of the fetal trunk past the navel is outside the body of the mother, for the purpose of performing an overt act that the person knows will kill the partially delivered living fetus[,] 18 U.S.C. § 1531(b)(1)(A), and is prohibited unless “necessary to save the life of a mother whose life is endangered by a physical disorder, physical illness, or physical injury,” 18 U.S.C. § 1531(a). - 34 -

previability abortion cannot coexist with the federal ban on partialbirth abortion. Neither the Sponsor nor any of the proponents addressed the Center for Life's argument. Assuming congressional preemption is even an appropriate consideration for this Court in assessing facial validity,6 there is no basis for accepting the Center for Life's argument here. For a provision of state law, including a state constitutional amendment, “to be held facially unconstitutional, the challenger must demonstrate that no set of circumstances exists in which the [provision] can be constitutionally applied." Abdool v. Bondi, 141 So. 3d 529, 538 (Fla. 2014). The federal prohibition on partial-birth abortion would by no means invalidate the proposed amendment in all its applications. 6. As a threshold issue, no one has briefed whether section 16.061 uses the phrase "invalid under the United States Constitution" to include any proposed amendment that would be preempted by an act of Congress or if that phrase should instead be interpreted to apply only if a proposed amendment is in conflict with a substantive provision of the United States Constitution. See Advisory Op. to Att'y Gen. re: Adult Personal Use of Marijuana, SC2023-0682, at 16 note 7 (Apr. 1, 2024). - 35

III. CONCLUSION We conclude that the proposed amendment complies with the single-subject requirement of article XI, section 3 of the Florida Constitution, and that the ballot title and summary comply with section 101.161(1), Florida Statutes. And there is no basis for concluding that the proposed amendment is facially invalid under the United States Constitution. Accordingly, we approve the proposed amendment for placement on the ballot. No rehearing will be permitted. It is so ordered. CANADY, LABARGA, and COURIEL, JJ., concur. MUÑIZ, C.J., concurs with an opinion, in which CANADY and COURIEL, JJ., concur. GROSSHANS, J., dissents with an opinion, in which SASSO, J., concurs. FRANCIS, J., dissents with an opinion. SASSO, J., dissents with an opinion, in which GROSSHANS and FRANCIS, JJ., concur. MUÑIZ, C.J., concurring. Animating the majority's decision today is the constitutional principle that “[a]ll political power is inherent in the people.” Art. I, § 1, Fla. Const. A judge's obedience to that principle does not signal personal indifference to the objective justice of a proposed - 36

constitutional amendment. It also does not imply that our legal tradition views considerations of justice as irrelevant to legal interpretation. See, e.g., Bancroft Inv. Corp. v. City of Jacksonville, 27 So. 2d 162, 171 (Fla. 1946) (“If the positive law (constitution or statute) does not give a direct answer to the question, the court is at liberty on the factual basis to indulge the rule of reason to reach a result consonant with law and justice.”). Instead, our Court's constrained role in the amendment process is dictated by the limited authority and task the people have assigned us. By contrast, questions of justice are appropriately at the heart of the voters' assessment of a proposed amendment like the one under review. With its reference to the existence of “inalienable rights” in all persons, our constitution's Declaration of Rights assumes a pre-constitutional, objective moral reality that demands our respect-indeed, a moral order that government exists to protect. The proposed amendment would constitutionalize restrictions on the people's authority to use law to protect an entire class of human beings from private harm. It would cast into doubt the people's authority even to enact protections that are prudent, compassionate, and mindful of the complexities involved. Under - 37 -

our system of government, it is up to the voters—not this Court-to decide whether such a rule is consistent with the deepest commitments of our political community. With these considerations in mind, we fully concur in the Court's opinion. CANADY and COURIEL, JJ., concur. GROSSHANS, J., dissenting. In the decades after Roe v. Wade was decided, abortion was rarely an issue on which the public made decisions—either directly or through their elected representatives. See Roe, 410 U.S. 113 (1973). Instead, the courts acted as policymakers, and judges determined the boundaries and scope of abortion regulations. However, courts were unable to settle the complicated issues surrounding abortion, and even the U.S. Supreme Court struggled to justify the constitutional basis for such a right. See id. at 153 (holding that abortion is a constitutional right as part of the “right of privacy"); Planned Parenthood of Se. Pa. v. Casey, 505 U.S. 833, 846 (1992) (joint opinion) (“Constitutional protection of the woman's decision to terminate her pregnancy derives from the Due Process Clause of the Fourteenth Amendment." (emphasis added)); cf. Dobbs - 38 -

v. Jackson Women's Health Org., 597 U.S. 215, 279 (2022) ("The Court [in Casey] abandoned any reliance on a privacy right and instead grounded the abortion right entirely on the Fourteenth Amendment's Due Process Clause."). Stressing these points and others, the Supreme Court relinquished the power that Roe claimed—returning the issue of abortion "to the people and their elected representatives." See Dobbs, 597 U.S. at 259. Now, in the post-Dobbs era, citizens must wrestle with how to balance the compelling interests of bodily autonomy and unborn life, while considering scientific advances, policy choices, and serious ethical implications. Cf. Casey, 505 U.S. at 979 (Scalia, J., concurring in the judgment in part and dissenting in part) (“The permissibility of abortion, and the limitations upon it, are to be resolved like most important questions in our democracy: by citizens trying to persuade one another and then voting."). These are difficult issues, and both sides of the debate have acted, at times rashly, in an attempt to resolve an issue on which there is little consensus. And we are reminded, yet again, what has been acknowledged by the Supreme Court many times— - 39 -

abortion is fundamentally different. See Dobbs, 597 U.S. at 257; Roe, 410 U.S. at 159; Casey, 505 U.S. at 852 (joint opinion). Today, we consider an initiative that proposes to amend our constitution by providing express protection for abortion procedures. The proposed amendment, with one exception, broadly forbids any “law” “prohibit[ing], penaliz[ing], delay[ing], or restrict[ing] abortion before viability or when necessary to protect the patient's health, as determined by the patient's healthcare provider." We have described our role in these advisory opinions as narrow. We determine if the proposed amendment meets our constitution's single-subject requirement and assess whether the ballot summary offers an explanatory statement of the amendment's chief purpose. See In re Advisory Op. to Att'y. Gen. re Use of Marijuana for Debilitating Med. Conditions, 181 So. 3d 471, 478 (Fla. 2015); cf. art. XI, § 3, Fla. Const. (single-subject rule); § 101.161, Fla. Stat. (2023) (requiring summary to set forth "explanatory statement . . . of the chief purpose of the measure”). Nevertheless, as revealed by our precedent, the precise scope of our review in this advisory role is subject to debate. The majority - 40 -

implies that we check to see if the summary and title track the amendment's text. See majority op. at 23-24 (collecting cases which involved summaries that tracked the proposed amendments). However, in a long line of decisions, we have consistently interpreted our role to be more comprehensive and have examined the material legal effects of the amendment—thereby ensuring that the voters are not misled and have fair notice of the decision before them on the ballot. See, e.g., Wadhams v. Bd. of Cnty. Comm'rs of Sarasota Cnty., 567 So. 2d 414, 416 (Fla. 1990); Dep't of State v. Fla. Greyhound Ass'n, Inc., 253 So. 3d 513, 520 (Fla. 2018) (“Ballot language may be clearly and conclusively defective either in an affirmative sense, because it misleads the voters as to the material effects of the amendment, or in a negative sense by failing to inform the voters of those material effects." (emphasis added)); Advisory Op. to Att'y Gen. re Prohibits Possession of Defined Assault Weapons (Assault Weapons), 296 So. 3d 376, 381 (Fla. 2020) (same). As Justice Sasso notes in her dissent, no party in this case has argued that our precedent applying this approach in ballot-summary review is erroneous. And under this approach, we have found both citizens' initiative proposals and legislatively proposed ballot - 41 -

initiatives to be defective. Yet, to my knowledge, the Legislature has not acted to restrict or narrow this Court's role in reviewing a ballot summary, nor has it attempted to clarify that our interpretation is improper. Accordingly, our precedent supports the conclusion that our statutory duty requires more than simply inspecting the summary for technical compliance. Instead, we determine if the summary clearly explains the chief purpose of the amendment. This will, at times, require the summary do more than simply echo the amendment's text. We have stated many times that the summary and title must be accurate and informative so that the “electorate is advised of the true meaning, and ramifications, of an amendment.” See, e.g., Advisory Op. to Att'y Gen. re Tax Limitation, 644 So. 2d 486, 490 (Fla. 1994) (emphasis added); Advisory Op. to Att'y Gen. re Med. Liab. Claimant's Comp. Amend., 880 So. 2d 675, 679 (Fla. 2004) ("These requirements make certain that the ‘electorate is advised of the true meaning, and ramifications, of an amendment.’” (quoting Tax Limitation, 644 So. 2d at 490)); Detzner v. League of Women Voters of Fla., 256 So. 3d 803, 807 (Fla. 2018) (same). And I - 42 -

acknowledge that the summary "need not explain every detail or ramification of the proposed amendment" so long as they "give the voter fair notice of the decision he or she must make." Detzner, 256 So. 3d at 807 (citations omitted). However, I disagree with the majority's suggestion that if the summary is an “almost verbatim recitation of the text of the proposed amendment” it cannot be misleading. Majority op. at 23. The majority finds that a parroting summary cannot be affirmatively "mislead[ing] . . . regarding the actual text of the proposed amendment." Id. That, however, fails to address if the summary negatively misleading for omitting material legal effects. And in declining to consider this point, the majority distinguishes our opinion in Advisory Opinion to the Attorney General re Adult Use of Marijuana, 315 So. 3d 1176 (Fla. 2021) (rejecting a summary for omitting material language found in the amendment), seemingly characterizing that case as the axiomatic example of misleading by omission. is The majority also does not account for the numerous other cases that have rejected summaries for misleading by omission, and others that have approved summaries while reaffirming that - 43 -

doctrine. We have repeatedly reaffirmed the broader holding that summaries must tell voters the amendment's legal effects. See, e.g., Evans v. Firestone, 457 So. 2d 1351, 1355 (Fla. 1984) (the summary "should tell the voter the legal effect of the amendment, and no more"); Advisory Op. to Att'y Gen. re Fla. Marriage Prot. Amend., 926 So. 2d 1229, 1238 (Fla. 2006) (same); Assault Weapons, 296 So. 3d at 381 (ballot can be clearly and conclusively defective “in a negative sense by failing to inform the voters [of] material effects of the amendment" (quoting Advisory Op. to Att'y Gen. re Right to Competitive Energy Mkt. for Customers of Inv'r-Owned Utils., 287 So. 3d 1256, 1260 (Fla. 2020)); Greyhound, 253 So. 3d at 520 (same). Although we have indicated that parroting the language of an amendment in the summary may easily satisfy the misleading prong,7 we have never claimed that doing so would always be 7. See Advisory Op. to Att'y Gen. re Voting Restoration Amend., 215 So. 3d 1202, 1208 (Fla. 2017) (“[T]he ballot title and summary also do not mislead voters with regard to the actual content of the proposed amendment. Rather, together they recite the language of the amendment almost in full."); Advisory Op. to Att'y Gen. re Prohibiting State Spending for Experimentation that Involves the Destruction of a Live Hum. Embryo, 959 So. 2d 210, 214 (Fla. 2007) (upholding a summary that contained language identical to that in the proposed amendment); Fla. Marriage Prot. Amend., 926 So. 2d at 1236-40 (upholding a summary that reiterated almost all of the - 44 -

sufficient to satisfy the statutory requirements. For example, in Wadhams, we found that even though a ballot contained "the entire section as it would actually appear subsequent to amendment," it still "fail[ed] to contain an explanatory statement of the amendment" and thus was “deceptive, because although it contains an absolutely true statement, it omits to state a material fact necessary in order to make the statement made not misleading." 567 So. 2d at 416; see also Armstrong v. Harris, 773 So. 2d 7, 15-16, 18 (Fla. 2000).8 Nor have we receded from our cases requiring the summary to inform the voter as to material legal effects. See Live Human Embryo, 959 So. 2d at 215. Sometimes a verbatim summary will capture the material legal effects contained in the amendment. But sometimes it will not. See, e.g., Wadhams, 567 So. 2d at 416. language contained in the amendment); Advisory Op. to Att'y Gen. re Med. Liab. Claimant's Comp. Amend., 880 So. 2d at 679 (same). 8. Even where we have upheld a ballot summary, we have still reaffirmed Wadhams and its logic, reiterating our precedents against parroting while approving a summary because it “is an accurate description of what the proposed amendment will do, consistent with the requirement that ballot language accurately represent the main legal effect and ramifications of a proposed amendment." Detzner v. Anstead, 256 So. 3d 820, 824 (Fla. 2018) (emphases added) (first citing Armstrong, 773 So. 2d at 12; and then citing Wadhams, 567 So. 2d at 417-18). - 45 -

Turning to this ballot summary, the vagueness of the proposed amendment itself leaves many key issues undetermined. Thus, as Justice Sasso notes, we ask: “[I]s the Sponsor relieved of its obligation to explain the legal effect of the proposed amendment just because the amendment has no readily discernable meaning?” Dissenting op. at 75-76 (Sasso, J.) Like Justice Sasso, I conclude the answer is no and agree with her detailed analysis that the summary's language fails to convey the amendment's ramifications to the voter. The majority implies that I am concerned only with "ambiguity in the text of the amendment" itself. Majority op. at 33. That is not so. On the contrary, it is the summary that has failed to adequately explain the amendment. In my view, the summary does not give the voter any clarity on the decision they must actually make or reveal the amendment's chief purpose. Instead, it misleads by omission and fails to convey the breadth of what the amendment actually accomplishes to enshrine broad, undefined terms in our constitution that will lead to decades of litigation. A voter may think this amendment simply returns Florida to a pre-Dobbs status quo. It does not. A voter may think that a - 46 -

healthcare provider would be clearly defined as a licensed physician specializing in women's health. It is not. A voter may think that viability falls within a readily apparent time frame. It does not. A voter may think that the comma is an insignificant grammatical tool that would have very little interpretive purpose. It will not. And, critically, the voter may think this amendment results in settling this issue once and for all. It does not. Instead, this amendment returns abortion issues back to the courts to interpret scope, boundary, definitions, and policy, effectively removing it from the people and their elected representatives. Perhaps this is a choice that Floridians wish to make, but it should be done with clarity as to their vote's ramifications and not based on a misleading ballot summary. To be clear, I do not criticize the content of the proposed amendment itself. The amendment's sponsors may draft an amendment as they see fit. But, contrary to the majority's assessment, it would seem "common sense” that the language a sponsor chooses clearly affects what must be included in the summary to meet the statutory requirements. The sponsor's burden to properly summarize the material legal effects of a - 47 -

proposed amendment is not lessened by its decision to include undefined terms or broad, abstract language. Moreover, the breadth of this amendment would likely impact existing constitutional provisions. Article I, section 2, a provision of our constitution's Declaration of Rights, states that “[a]ll natural persons. are equal before the law and have inalienable rights,” including “the right to enjoy and defend life.” Art. I, § 2, Fla. Const. We have held time and again that a summary must “identify the provisions of the constitution substantially affected by the proposed amendment.” Right of Citizens to Choose Health Care Providers, 705 So. 2d at 566 (citing Tax Limitation, 644 So. 2d at 490). This is required “in order for the public to fully comprehend the contemplated changes.” Id.⁹ 9. The requirement that a summary list substantially affected provisions is so embedded in our jurisprudence that some older cases have described it as being rooted in our constitution. See Fine v. Firestone, 448 So. 2d 984, 989-90 (Fla. 1984); Tax Limitation, 644 So. 2d at 490; Advisory Op. to Att’y Gen. re Right of Citizens to Choose Health Care Providers, 705 So. 2d 563, 565-66 (Fla. 1998) (reiterating that "it is imperative that an initiative identify the provisions of the constitution substantially affected by the proposed amendment”); Advisory Op. to Att'y Gen. re Amend. to Bar Gov't from Treating People Differently Based on Race in Pub. Educ., 778 So. 2d 888, 892 (Fla. 2000) (same). More recently, we have found that the modern clarity statute requires the same rule. - 48 -

The amendment's potential effects on article I, section 2 have present significance, even though we don't have the benefit of a robust body of case law on the topic. That is, the public should be made aware that the scope of the amendment could, and likely would, impact how personhood is defined for purposes of article I, section 2 of our constitution. The voters are owed that "candor and accuracy." See majority op. at 27 (quoting Greyhound, 253 So. 3d at 520). I do not deny that the return of abortion policy to the states in the wake of Dobbs has resulted in a minefield of potential issues, many of which are “unsettled." Majority op. at 32 n.3. As I previously discussed, citizens have not been asked to contend with these questions in decades. In similar fashion, this Court has failed to address whether the rights guaranteed in article I, section 2 apply to the unborn and, if so, what the scope of those rights could See Treating People Differently Based on Race, 778 So. 2d at 898 (rejecting a ballot summary as misleading under section 101.161 because it failed to mention its effect on article I, section 2's nondiscrimination provision; concluding that “the ballot titles are defective because of the misleading negative implication that no such constitutional provision addressing differential treatment currently exists"). - 49 -

be. However, our failure to decide on this issue does not render the provision void. Nor does it alleviate a sponsor's duty to advise the voter of impact. Nowhere has this requirement to inform been arbitrarily limited to substantial effects on issues that this Court has already weighed in on. Cf. Greyhound, 253 So. 3d at 523 (evaluating substantial effect on then-recently added article X, section 23, and citing no cases for its interpretation). While a substantial effect would be even more obvious if we had previously addressed this issue, our silence should not eliminate a citizen's right to be informed. If advised of the conflict, the voter could recognize for themselves that, at some level, an amendment providing broad protection for abortion would bear upon constitutional personhood rights as applied to the unborn child. Thus, the voter would be able to consider the choice before them and the decision they must make. See Fine, 448 So. 2d at 989. Accordingly, I cannot say that failing to inform voters as to the proposed amendment's impact on article I, section 2 is acceptable. In summary, Floridians have the right to amend their constitution through the initiative process, and it is an integral part of our state's commitment to responsible citizenship. However, - 50 -

there are constitutional and statutory requirements that must be satisfied in order for an amendment to reach the ballot. Holding a sponsor to those requirements is far from what the majority characterizes as a “stranglehold on the amendment process." See majority op. at 33. Consequently, I find the ballot summary conclusively defective for failing to inform the voter of the material legal effects of the amendment, including the substantial effect this amendment could have on article I, section 2 of our constitution. This conclusion requires me to respectfully dissent from the majority's opinion. SASSO, J., concurs. FRANCIS, J., dissenting. The issue of abortion is incredibly divisive. See Dobbs v. Jackson Women's Health Org., 597 U.S. 215, 292 (2022) (“Roe [v. Wade, 410 U.S. 113 (1973)] 'inflamed' a national issue that has remained bitterly divisive for the past half century. And for the past 30 years, [Planned Parenthood of Se. Pa. v.] Casey [505 U.S. 883 (1992)] has done the same.” (citations omitted)). When Dobbs found there was no federal constitutional right to it, the Court "return[ed] the issue of abortion to the people's elected - 51

representatives." Id. at 232. Our elected representatives here in Florida did address the issue of abortion legislatively. See §§ 390.011-.0111, .0112, Fla. Stat. (2023). But those laws have faced legal challenges. Simultaneously, groups have undertaken the use of the initiative process, see art. XI, § 3, Fla. Const., to enshrine abortion in our state constitution. Today, we are asked to opine on one such effort-an Amendment to Limit Government Interference with Abortion. 10 As written, the title and the ballot summary (which parrots the amendment) fail to give the voters what they need to make an 10. Specifically, we must determine whether the language of this proposed amendment embraces but one subject, see art. XI, § 3, Fla. Const., and whether the ballot summary explains the “chief purpose" of the proposed amendment in clear, unambiguous, nonmisleading terms, § 101.161(1), Fla. Stat. (2023). The short ballot title must also be clear, unambiguous, and non-misleading. Together, the ballot summary and title must “ ‘provide fair notice of the content of the proposed amendment' to voters so that they will not be misled as to [the proposed amendment's] purpose, and can cast an intelligent and informed ballot.'” Advisory Op. to Att'y Gen. re Voter Control of Gambling, 215 So. 3d 1209, 1215 (Fla. 2017) (alteration in original) (emphasis added) (quoting Advisory Op. to Att'y Gen. re Right of Citizens to Choose Health Care Providers, 705 So. 2d 563, 566 (Fla. 1998)). - 52 -

informed decision; thus, both violate the truth-in-packaging law. § 101.161(1), Fla. Stat. The title fails to communicate to the voters that the purpose of the proposed amendment is ending (as opposed to “limiting”) legislative and executive action on abortion, while inviting limitless and protracted litigation in the courts because of its use of vague and undefined terms. Just as it played out on the federal stage for over 50 years, the issue of abortion-far from the people settling the matter will continue to be decided by each iteration of this Court. And the summary hides the ball as to the chief purpose of the proposed amendment: which, ultimately, is to for the first time in Florida history-grant an almost unrestricted right to abortion. 11 Because the summary only parrots the language of the proposed amendment, it explains nothing, and does not disclose its chief purpose. See § 101.161(1), Fla. Stat. The fact that the 11. I disagree with the majority's conclusions that "the broad sweep of this proposed amendment is obvious in the language of the summary," majority op. at 19, and that "[t]he ballot title's inclusion of the word 'limit' is . . . not misleading but accurately explains that the Legislature will retain authority to interfere[] with’ abortions under certain circumstances." Majority op. at 21 (second alteration in original). - 53 -

language has a "broad sweep," see majority op. at 19, as to its "no law" restriction, to me, doesn't end the inquiry. Rather, the sponsor is statutorily and constitutionally required to provide the voter an explanation of the summary's vague language (e.g., as to what constitutes "health" or who may qualify as a “healthcare provider”), as well as tell the voter of the amendment's chief effects. This is not some run-of-the-mill restoration of Roe-it goes far beyond that into uncharted territory in this State. As to the majority's statement that the Court cannot place a "stranglehold" on the initiative process, majority op. at 33, I could not agree more! But this is not that. It is my view that while the constitution enshrines the reserved right of the people to amend their constitution, this Court also has a role in ensuring the people can exercise that right free of anything that would mislead them or present them with ambiguity. See art. V, § 3(b)(10), art. IV, § 10, art. XI, § 3, Fla. Const.; § 101.161, Fla. Stat. 12 And quite simply, 12. See supra note 10. 54 -

for the reasons expressed in greater detail here and elsewhere, the summary and title, I submit, don't pass muster. 13 The effects I discern from the parroted-proposed-amendment summary here-which effects are the best evidence of its chief purpose—are fourfold: (1) to immediately abrogate meaningful abortion laws and restrictions; (2) to eliminate any meaningful, future participation by the Legislature by prohibiting any laws on previability abortions and subjecting any laws regulating postviability abortions to a "healthcare provider's" veto; (3) to—by eliminating the Legislature’s interference—vastly expand the right to abortion at any time during pregnancy as a "health" issue for the mother; and 13. I also remain convinced that our precedent has read the single-subject requirement far too broadly. However, as I tackle that topic in my dissent in Advisory Opinion to the Attorney General re Adult Personal Use of Marijuana, SC2023-0682 (Apr. 1, 2024) (Francis, J., dissenting), I limit my dissent here to the proposal's violation of the truth-in-packaging provisions. - 55

(4) troublingly, to—by ignoring the State's legitimate interests in protecting life-completely redefine abortion as a health issue in Florida without saying so. I address these four effects—that are left unexplained by the summary—in part I, below. And in part II, I further address why the title will mislead voters. I. Ballot Summary (1) First, the ballot summary doesn't explain that the scope and immediate impact of the “no law” language is to abrogate Florida’s current prohibitions, restrictions, and regulations on both pre and postviability abortions. This includes current laws defining viability and drawing the line at a certain number of weeks, §§ 390.011(15), .0111(1), Fla. Stat. (2023); those requiring a sonogram and informed consent, § 390.0111(3), Fla. Stat. (2023); and those prohibiting abortions postviability with limited exceptions. §§ 390.0111(1)(a)-(c), .0112, Fla. Stat. (2023). The summary also provides that the Legislature can't make laws interfering with a “healthcare provider's" determination that a 56

late term abortion is medically necessary for the sake of the patient's "health." "Health" is undefined and, thus, not limited to just lifethreatening physical conditions. Rather, “health” could mean anything, really. And “health" seems to include nebulous conditions that could be used to justify a late term abortion. The ballot summary does not explain this. (2) Second, the ballot summary doesn't explain that the proposed amendment effectively eliminates the Legislature's ability to pass laws in the future regulating abortion in any meaningful, substantive way. This prohibition applies to previability pregnancies. But it applies to postviability pregnancies, too, because the undefined "healthcare provider” gets a veto over any laws the Legislature might be able to pass to protect the unborn as long as said "healthcare provider" decides a "health" issue exists necessitating an abortion. 14 The ballot summary does not explain this. 14. I completely agree with Justice Sasso's excellent dissent concerning the vagueness of the language used by the sponsor, - 57 -

(3) Third, the ballot summary doesn't explain that by eliminating the Legislature's ability to meaningfully pass laws regulating abortion either pre or postviability, and housing the proposed amendment under Article I's “Declaration of Rights” in the Florida Constitution, the amendment vastly expands the right to abortion beyond anything Florida has ever done in the history of the State. Whatever limits on the “right” to abortion remain are placed squarely in the “healthcare provider's” hands as ultimate decisionmaker. The ballot summary neither explains nor discloses this. (4) Fourth, the summary doesn't explain that the proposed amendment implicitly and completely redefines the abortion issue as a "patient's health" issue without acknowledging what even Roe and Casey acknowledged: the State's compelling interest in though, arguendo, for purposes of my dissent, I assume that the placement of the comma means the worst-case scenario: the "healthcare provider" also determines viability. See dissenting op. at 74-75 (Sasso, J.). - 58 -

protecting “the potentiality of human life," particularly viable pregnancies. See Dobbs, 597 U.S. at 228, 271 (defining "viability" as the ability to survive outside the womb). 15 While I recognize that our review in ballot initiative cases is narrow, this case is different because abortion is different. Dobbs, 597 U.S. at 218 (Syllabus) (“Abortion is different because it destroys what Roe termed 'potential life'. . . . None of the other decisions cited by Roe and Casey involved the critical moral question posed by abortion."). The exercise of a “right” to an abortion literally results in a devastating infringement on the right of another person: the right to live. And our Florida Constitution recognizes that “life” is a “basic right” for “[a]ll natural persons.” Art. I, § 2, Fla. Const. One must recognize the unborn's competing right to life and the State's moral duty to protect that life. 15. Roe found that “in ‘the stage subsequent to viability,' which in 1973 roughly coincided with the beginning of the third trimester, the State's interest in the 'potentiality of human life’ became compelling, and therefore a State could 'regulate, and even proscribe, abortion except where it is necessary, in appropriate medical judgment, for the preservation of the life or health of the mother."" Dobbs, 597 U.S. at 271 (citing Roe, 410 U.S. at 164-65). - 59 -

Contrary to what the summary—which parrots the proposed amendment—suggests, abortion is not just about a medical procedure, and it is not just about the rights of women to bodily integrity. "Abortion presents a profound moral issue on which Americans hold sharply conflicting views." Dobbs, 597 U.S. at 223.¹6 The summary does not address this. Instead, it is a Trojan horse for the elimination of any recognition of the State's interest in protecting what Roe termed "potential life." II. Title Based on the four points above, it is clear that the title is also misleading in its use of the term “limit government interference." A more truthful title may be “eliminating the Legislature's ability to regulate abortion in any meaningful way." 16. "Some believe fervently that a human person comes into being at conception and that abortion ends an innocent life.” Id. at 223-24. "Others feel just as strongly that any regulation of abortion invades a woman's right to control her own body and prevents women from achieving full equality." Id. at 224. "Still others in a third group think that abortion should be allowed under some but not all circumstances, and those within this group hold a variety of views about the particular restrictions that should be imposed.” Id. at 223-25. - 60 -

Beyond this, the current title isn't even accurate because it does not limit government interference: it actively encourages it. This is so because the prohibition on the law- and rule-making authority of the legislative and executive branches does not extend to the judicial branch. In fact, quite the opposite: the summarywhich parrots the amendment—reflects multiple undefined terms that invite protracted litigation and, thus, limitless interference by the judicial branch of government. This is exactly what happened after Roe, when abortion was recognized as a fundamental right under the United States Constitution. It led to 50 years of protracted litigation and to the courts continually policing state provisions seeking to protect the lives of both the unborn and their mothers. 17 17. See, e.g., Planned Parenthood of Cent. Mo. v. Danforth, 428 U.S. 52 (1976) (blocking Missouri law requiring spousal consent for abortion); Maher v. Roe, 432 U.S. 464 (1977) (reversing decision striking a Connecticut law that excluded abortion services from Medicaid coverage); Colautti v. Franklin, 439 U.S. 379 (1979) (striking Pennsylvania law requiring physicians to save the life of a potentially viable fetus as unconstitutionally vague); Harris v. McRae, 448 U.S. 297 (1980) (upholding federal law proscribing federal funding for abortions except for abortions necessary to either preserve the mother's life or terminate pregnancies resulting from rape or incest); H.L. v. Matheson, 450 U.S. 398 (1981) (upholding Utah law requiring parental notification when the - 61

After Dobbs returned the abortion issue to the states, both abortion proponents and opponents identified the states as the new abortion battleground and started filing lawsuits in the courts. 18 patient is a minor living with parents); City of Akron v. Akron Ctr. for Reprod. Health, Inc., 462 U.S. 416 (1983) (striking portions of Ohio law imposing limitations, such as a waiting period, parental consent without judicial bypass, and a ban on abortions outside of hospitals after the first trimester); Thornburgh v. Am. Coll. of Obstetricians and Gynecologists, 476 U.S. 747 (1986) (striking Pennsylvania law requiring informed consent to include information about fetal development and alternatives to abortion); Webster v. Reprod. Health Servs., 492 U.S. 490 (1989) (upholding Missouri law that required physician viability testing and blocked state funding and state facility participation in abortion services); Casey, 505 U.S. 833 (announcing "undue burden" test in landmark case striking portions of Pennsylvania abortion law); Hill v. Colorado, 530 U.S. 703 (2000) (upholding Colorado law limiting protest and leafletting close to an abortion clinic); Stenberg v. Carhart, 530 U.S. 914 (2000) (striking Nebraska law banning partial birth abortion); Gonzales v. Carhart, 550 U.S. 124 (2007) (upholding 2003 federal law banning partial birth abortion). 18. See Center for Reproductive Rights, New Digital Tool Provides State-by-State Analysis of High Court Rulings on Abortion, https://reproductiverights.org/state-constitutions-abortion-rightsdigital-tool (last visited Mar. 14, 2024) (“Since the U.S. Supreme Court eliminated the federal constitutional right to abortion in its 2022 ruling in Dobbs v. Jackson Women's Health Organization, states have become the battlegrounds for abortion rights."); Alliance Defending Freedom, "What You May Not Know: How ADF Helped Overturn Roe v. Wade," https://adflegal.org/article/what-you-maynot-know-how-adf-helped-overturn-roe-v-wade (last visited Mar. 27, 2024) (“Roe v. Wade has finally been overturned. But this does not mean the work of the pro-life movement is over—far from it . .”; playing video of ADF CEO, President, and General Counsel Kristen - 62 -

Those state lawsuits began immediately. 19 According to the Brennan Center for Justice's “State Court Abortion Litigation Waggoner explaining that there are now generally four areas of abortion laws that will be litigated post-Dobbs: (1) trigger laws (state laws with provisions restricting or prohibition abortion to some degree upon Roe being overturned); (2) pre-Roe laws limiting abortion; (3) post-Roe/pre-Dobbs laws stricken under Roe; and (4) post-Dobbs (new) laws restricting and regulating abortions); Becky Sullivan, "With Roe Overturned, State Constitutions Are Now at the Center of the Abortion Fight,” https://www.npr.org/2022/06/29/1108251712/roe-v-wade abortion-ruling-state-constitutions (last visited Mar. 14, 2024) ("Now, with Roe v. Wade overturned, the legal spotlight has shifted to the states, where abortion supporters and opponents must contend with 50 different constitutions that, in many places, guarantee rights more broadly than their federal counterpart.”); see also David S. Cohen et. al., The New Abortion Battleground, 123 Colum. L. Rev. 1, 2–3 (2023) (predicting that “interjurisdictional abortion wars are coming” now that there is no longer a national, uniform abortion right, which will involve intervention by the federal government). 19. See American Civil Liberties Union (ACLU), “Reproductive Rights Organizations Go to Court in 11 States to Protect Abortion Access in Aftermath of Roe v. Wade Falling,” https://www.aclu.org/press-releases/reproductive-rightsorganizations-go-court-11-states-protect-abortion-access (last visited Mar. 14, 2024) (“This week, following the U.S. Supreme Court's decision to overturn Roe v. Wade and eliminate the federal constitutional right to abortion, Planned Parenthood Federation of America (PPFA), the American Civil Liberties Union, and the Center for Reproductive Rights (CRR) took legal action to block abortion bans in 11 states: Arizona, Idaho, Kentucky, Louisiana, Mississippi, Ohio, Oklahoma, Florida, Texas, Utah, and West Virginia. So far, these efforts have successfully blocked abortion bans in five states Utah, Kentucky, Louisiana, Florida, and Texas-through - 63 -

Tracker," "[a]s of January 11, 2024, a total of 40 cases have been filed challenging abortion bans in 23 states, of which 22 remain pending at either the trial or appellate levels."20 In fact, Planned Parenthood of Southwest Florida v. State of Florida, No. 2022-CA000912 (Fla. 2d Cir. Ct.),21 is one of the cases filed immediately after Dobbs in which abortion proponents succeeded in obtaining a temporary restraining order from a Florida trial court to keep a fifteen-week abortion ban from going into effect. All of this illustrates that the proposed amendment will not do what the Sponsor and the title say it will do. Instead of limiting government interference, it will ultimately encourage a great deal of interference by the judicial branch. So, I must conclude the title is misleading. temporary restraining orders, allowing some providers there to resume abortion care for now."); Becky Sullivan, supra note 18 ("The legal chaos has already begun. In a half-dozen states and counting, lawsuits argue that new restrictive abortion laws are in violation of state constitutions."). 20. https://www.brennancenter.org/our-work/research reports/state-court-abortion-litigation-tracker (last visited Mar. 14, 2024); see also supra note 19. 21. Review was granted by this Court in SC2022-1050. - 64 -

III. Conclusion In sum, the Sponsor is required to tell the truth about the purpose and scope of the proposed amendment and not mislead voters; it has done neither. For these reasons, I dissent. SASSO, J., dissents with an opinion. SASSO, J., dissenting. After a sincere assessment of this case, I conclude that the Sponsor's cut-and-paste approach to preparing the ballot summary fails to satisfy its legal obligation to provide an explanatory statement of the proposal's chief purpose. For that reas ason, and with the utmost respect for the majority's decision to the contrary, I respectfully dissent. I. This case is somewhat unprecedented. Since this Court first stepped into its role reviewing ballot summaries in the citizen initiative context, we have not been presented with an amendment quite like this. What makes the amendment unique is not its controversial subject matter; this Court has considered controversial amendments before. Instead, it is unique because of - 65 -

the proposed amendment's overwhelmingly vague and ambiguous language and structure. In essence, the Sponsor has submitted a proposal with no readily discernable meaning, leaving it up to courts to determine even its most essential legal effects over time. The challenge, then, is to evaluate whether the summary meets the requirements of section 101.161, Florida Statutes (2023), when we have said that in doing so we evaluate “objective criteria inherent in the amendment itself,” Advisory Op. to Att'y Gen. re Citizenship Requirement to Vote in Fla. Elections, 288 So. 3d 524, 529 (2020) (quoting Fla. Dep't of State v. Fla. State Conf. of NAACP Branches, 43 So. 3d 662, 667 (Fla. 2010)), to determine whether or not the ballot title and summary fairly inform the voter of the “true meaning, and ramifications, of an amendment," Askew v. Firestone, 421 So. 2d 151, 156 (Fla. 1982). To answer this question, I will explain what our precedent requires, 22 how that applies here, and why my decision is consistent with our role. 22. Critical to my determination in this case—no one has argued that our precedent is wrong. No one questions the constitutionality of section 101.161, no one argues that the requirements this Court has applied to ballot summaries do not - 66

II. A. When a sponsor submits a constitutional amendment to the voters, section 101.161 imposes on the sponsor the obligation to prepare a ballot summary of the proposed amendment. § 101.161(2), Fla. Stat. The requirements the sponsor must meet in preparing the summary are delineated in section 101.161(1), which provides: Whenever a constitutional amendment or other public measure is submitted to the vote of the people, a ballot summary of such amendment or other public measure shall be printed in clear and unambiguous language on the ballot after the list of candidates . . . . The ballot summary of the amendment or other public measure shall be an explanatory statement, not exceeding 75 words in length, of the chief purpose of the measure. Id. (emphases added). From this text, our Court has derived a few requirements. First, the statute requires an “explanatory statement" of the flow from the statutory text, and no one argues that this Court lacks the authority to prevent ballot summaries that fail to meet those requirements from being submitted to the voters. And while this Court's precedent related to citizen initiatives has been disjointed at best, because no one has argued that even one of this Court's decisions is clearly erroneous, I will do my best in this case to follow the common thread those cases provide. - 67 -

amendment's chief purpose. That is something distinct from an accurate replication of the proposed amendment. See, e.g., Wadhams v. Bd. of Cnty. Comm'rs of Sarasota Cnty., 567 So. 2d 414, 416 (Fla. 1990). Second, the ballot summary's explanatory statement must be clear and unambiguous. This means 1) the summary must not mislead the public, and 2) the ballot summary must fairly inform the voter of the chief purpose of the amendment. See Fla. Dep't of State v. Slough, 992 So. 2d 142, 147 (Fla. 2008) (quoting Advisory Op. to Att'y Gen. re Prohibiting State Spending for Experimentation that Involves the Destruction of a Live Hum. Embryo, 959 So. 2d 210, 213-14 (Fla. 2007)). And although the term “chief purpose" is undefined in the statute, this Court has filled in the gaps. For decades, this Court has described “chief purpose” to mean “the amendment's chief effect," Askew, 421 So. 2d at 155, and even more specifically to mean the "legal effect of the amendment," Evans v. Firestone, 457 So. 2d 1351, 1355 (Fla. 1984); see also Advisory Op. to Att'y Gen. re All Voters Vote in Primary Elections for State Legislature, Governor, & Cabinet, 291 So. 3d 901, 913 (Fla. 2020) (Muñiz, J., dissenting) - 68

("[T]he 'chief purpose' of the amendment can be understood in terms of the subset of those legal effects that would be material to a reasonable voter."). In doing so, we have clarified that a sponsor “need not explain every detail or ramification of the proposed amendment." Advisory Op. to Att'y Gen. re Amend. to Bar Gov't from Treating People Differently Based on Race in Pub. Educ., 778 So. 2d 888, 899 (Fla. 2000) (quoting Advisory Op. to Att'y Gen. re Prohibiting Pub. Funding of Pol. Candidates' Campaigns, 693 So. 2d 972, 975 (Fla. 1997)). Even so, "drafters of proposed amendments cannot circumvent the requirements of section 101.161, Florida Statutes, by cursorily contending that the summary need not be exhaustive.” Id.; see also Dep't of State v. Fla. Greyhound Ass'n, 253 So. 3d 513, 520 (Fla. 2018) (a ballot summary that fails to inform the voter of an amendment's "material effects" is defective). Together, these requirements serve a greater purpose than guaranteeing the sponsor fulfills technical rules. Section 101.161 ensures that “[t]he voter should not be misled and . . . [will] have an opportunity to know and be on notice as to the proposition on which he is to cast his vote." Wadhams, 567 So. 2d at 417 - 69 -

(omission in original) (quoting Hill v. Milander, 72 So. 2d 796, 798 (Fla. 1954)). In other words, to make an informed decision, the voter must know the "true meaning, and ramifications, of an amendment.” Askew, 421 So. 2d at 156. B. Giving effect to these requirements, this Court has never hesitated to hold a sponsor to its statutory obligations. And this has been true particularly when presented with ballot summaries that contain vague and ambiguous language, even when that language closely mirrors the underlying proposal. For example, in Askew, a ballot summary closely followed the text of a proposed amendment that would prohibit former state officers from lobbying without disclosing financial interests. 421 So. 2d at 153. This Court still found the summary misleading because it neglected to advise the public of an existing two-year lobbying ban that did not require financial disclosures. Id. at 155. We concluded that "[t]he problem, therefore, lies not with what the summary says, but, rather, with what it does not say." Id. at 156. "[S]uch a change must stand on its own merits and not be disguised as something else." Id. - 70 -

And in Wadhams, similar to the Sponsor here, the amendment's proponents simply provided the text of the amendment without a summary. 567 So. 2d at 415. The Court held that a summary explaining the effects of the amendment was necessary, concluding: The problem with the ballot in the present case is much the same as the problem with the ballot in Askew. By containing the entire section as it would actually appear subsequent to amendment, rather than a summary of the amendment to the section, the ballot arguably informed the voters that the Charter Review Board would only be permitted to meet once every four years. By failing to contain an explanatory statement of the amendment, however, the ballot failed to inform the public that there was presently no restriction on meetings and that the chief purpose of the amendment was to curtail the Charter Review Board's right to meet. Similar to the ballot summary at issue in Askew, the present ballot “is deceptive, because although it contains an absolutely true statement, it omits to state a material fact necessary in order to make the statement made not misleading." Id. at 416 (quoting Askew, 421 So. 2d at 158 (Ehrlich, J., concurring)). In similar fashion, in 2018 a majority of this Court concluded that "it is not sufficient for a ballot summary to faithfully track the text of a proposed amendment.” Detzner v. League of Women Voters of Fla., 256 So. 3d 803, 811 (Fla. 2018). With that rule guiding its - 71 -

analysis, this Court held that a ballot summary was defective for failing to explain the phrase "established by" because that phrase "is neither commonly nor consistently used" and therefore "cannot be commonly understood by voters.” Id. at 809-10. Likewise, we determined the ballot summary failed to explain the categories of schools that would be affected by the proposal and therefore "voters will simply not be able to understand the true meaning and ramifications of the revision," so "the ballot language [was] clearly and conclusively defective." Id. at 810. This Court has also, at times, determined that ballot summaries fail when specific terms are left undefined. See, e.g., Advisory Op. to Att'y Gen. re People's Prop. Rts. Amends. Providing Comp. for Restricting Real Prop. Use May Cover Multiple Subjects, 699 So. 2d 1304, 1308-09 (Fla. 1997) (failure to define "owner," "common law nuisance,” and “in fairness” in the summary, even though those terms were properly replicated from and also undefined in the text of the proposed amendment, caused the amendment to be stricken from ballot); Race in Pub. Educ., 778 So. 2d at 899-900 ("[T]his Court has repeatedly held that ballot summaries which do not adequately define terms, use inconsistent - 72 -

terminology, fail to mention constitutional provisions that are affected, and do not adequately describe the general operation of the proposed amendment must be invalidated."); Smith v. Am. Airlines, Inc., 606 So. 2d 618, 621 (Fla. 1992) (observing the statutory word limit “does not give drafters of proposed amendments leave to ignore the importance of the ballot summary and to provide an abbreviated, ambiguous statement in the hope that this Court's reluctance to remove issues from the ballot will prevent us from insisting on clarity and meaningful information"). Of course, I recognize this Court did not deem any of those ballot summaries defective because they parroted language. Instead, the best I can do to synthesize our cases is to conclude that this Court has considered ballot summaries defective where, despite parroting, the summary either misled by omission, failed to explain the material ramifications of the amendment, or resulted in a disconnect between the operative meaning of a term and a voter's understanding of it. - 73

III. So, how do these principles apply here? A. The Sponsor argues that this Court's cases referenced in section II(B) are inapplicable because there is no ambiguity in the amendment. It argues that the terms “viability,” “healthcare provider," and "patient's health” all have clear meanings that are obvious to voters. Similarly, the Sponsor argues that the comma placed between “patient's health” and “as determined by the patient's healthcare provider” means that the term “viability" used earlier in the amendment is also modified by the phrase "as determined by the patient's healthcare provider." This too, says the Sponsor, is clear and obvious to the voter because of common rules of grammar. The Sponsor is just plain wrong. None of those terms have any sort of widely shared meaning,2³ nor do I think the comma 23. "Health" and "healthcare provider" have obviously broad and undefined boundaries which are seemingly unlimited without the benefit of a technical, legal analysis. As for “viability,” “[t]his arbitrary line has not found much support among philosophers and ethicists . . . . The most obvious problem with [relying on or attempting to define viability] is that viability is heavily dependent - 74 -

accomplishes what the Sponsor says it does.24 So if the ballot summary is sufficient in this case, it is not for the reasons the Sponsor has presented to this Court. B. The more difficult question is whether the ballot summary is sufficient because it parrots the proposed amendment, which itself is vague and ambiguous. In other words, is the Sponsor relieved of its obligation to explain the legal effect of the proposed amendment just because the amendment has no readily discernable meaning? In my view, the answer is no. I agree with the majority that, at on factors that have nothing to do with the characteristics of a fetus." Dobbs v. Jackson Women's Health Org., 597 U.S. 215, 27576 (2022). 24. Antonin Scalia & Bryan A. Garner, Reading Law: The Interpretation of Legal Texts (2012), a treatise devoted to the interpretation of legal text, identifies the application of the series qualifier canon as "highly sensitive to context." Id. at 150. This sensitivity to context is exemplified in Justice Alito's concurrence in Facebook, Inc. v. Duguid, 592 U.S. 395 (2021), where he lays out several examples of sentences that go against the canon. And so, application of the series qualifier canon is not so straightforward that all reasonable Florida voters will mechanistically apply this arcane rule and discover that, “indeed, ‘as determined by the patient's healthcare provider' also modifies 'viability.'" See id. at 413 (Alito, J., concurring) ("No reasonable reader interprets texts that way.”). - 75 -

a very high level, the voters will understand that this amendment creates a broad right to abortion in Florida. However, our precedent has consistently required that the summary explain more than the amendment’s general aim. Indeed, we have said that ballot summaries must explain the “material legal effect," so that the electorate is advised of the “true meaning, and ramifications, of an amendment" and is thereby "adequately informed." The summary here does none of this. Instead, it leaves the legally operative terms that define the amendment's scope (“viability,” “health,” and “healthcare provider”) up in the air. Likewise, the summary does not attempt to explain that the amendment itself is similarly vague and ambiguous, nor do I believe that this fact is self-evident from the vague and ambiguous nature of the summary. What we are left with, then, is a summary that does not attempt to explain the amendment's material legal effects and employs terms that are neither consistently nor commonly understood. As a result, I find it much more likely that this summary will mislead voters into committing the same error the Sponsor did in its briefing to this Court: they will carry their - 76 -

personal conception of the amendment's meaning into the voting booth, operating under the assumption that their particular interpretation is widely understood. Similarly, I find it highly unlikely that voters will understand the true ramifications of this amendment—that they will read the ballot summary and vote based on an informed understanding and acceptance of the uncertainties posed by its vague and ambiguous language. For that reason, I believe this case better fits with those decisions in which we concluded that ballot summaries were defective, rather than those relied upon by the majority. See, e.g., Race in Pub. Educ., 778 So. 2d at 899 (concluding an undefined term left "voters to guess at its meaning. ... [V]oters would undoubtedly rely on their own conceptions of what constitutes a bona fide qualification," and that the summary violated section 101.161); League of Women Voters, 256 So. 3d at 811; People's Prop. Rts. Amends., 699 So. 2d 1304; Askew, 421 So. 2d 151.25 25. The closest cases cited by the majority to this one are Advisory Opinion to the Attorney General re Medical Liability Claimant's Compensation Amendment, 880 So. 2d 675 (Fla. 2004), and Advisory Opinion to the Attorney General re Florida Marriage Protection Amendment, 926 So. 2d 1229 (Fla. 2006). I find Medical Liability distinguishable because the chief purpose of the - 77 -

And so, I conclude the Sponsor has failed to prepare a ballot summary that meets the requirements of section 101.161 as previously interpreted by this Court. IV. I will end by briefly touching upon one point in the majority opinion. The majority argues that if we conclude the summary is defective due to its vague and ambiguous nature, we may be inadvertently imposing a substantive limitation on what types of amendments can be proposed via the citizen initiative process. While I do not think this concern is totally unfounded, I also think the concern is more for the legislature than the judiciary. Again, no one challenges the constitutionality of section 101.161, and no one challenges this Court's precedent interpreting it. If a sponsor cannot fulfill its statutory obligation because its amendment was still communicated to the voter despite the undefined term. I find Marriage Protection Amendment distinguishable because the meaning of the undefined terms was clear to the ordinary voter. Likewise, I do not think Advisory Opinion to the Attorney General re Voter Control of Gambling, 215 So. 3d 1209 (Fla. 2017), provides helpful guidance because the undisclosed ambiguous legal effect in that case was retroactivitynot a legal effect that constituted a pillar of the amendment's scope, like viability, health, and healthcare provider here. - 78 -

proposed amendment is too vague and ambiguous to explain, I believe the statute places the burden of that bargain with the sponsor not the voters. See Smith, 606 So. 2d at 621 ("[T]he burden of informing the public should not fall only on the press and opponents of the measure the ballot title and summary must do this.” (quoting Askew, 421 So. 2d at 156)). And that is what happened here. The Sponsor has made no attempt to “explain” the material legal effects of the proposed ballot amendment as required by section 101.161. Instead, the Sponsor has punted, leaving the legal effect to be revealed by the eye of the beholder. The Sponsor's statutory obligation, as explained by this Court's precedent, demands more. As a result, I respectfully dissent. GROSSHANS and FRANCIS, JJ., concur. Original Proceeding - Advisory Opinion - Attorney General Ashley Moody, Attorney General, Henry C. Whitaker, Solicitor General, Jeffrey Paul DeSousa, Chief Deputy Solicitor General, Daniel W. Bell, Chief Deputy Solicitor General, Nathan A. Forrester, Senior Deputy Solicitor General, John M. Guard, Chief Deputy Attorney General, and James H. Percival, Chief of Staff, Office of the Attorney General, Tallahassee, Florida, for Petitioner - 79 -

Mathew D. Staver, Anita L. Staver, Horatio G. Mihet, and Hugh C. Phillips of Liberty Counsel, Orlando, Florida, for Interested Party, Florida Voters Against Extremism, PC Stephen C. Emmanuel of Ausley McMullen, Tallahassee, Florida, for Interested Party, Florida Conference of Catholic Bishops, Inc. Alan Lawson, Samuel J. Salario, Jr., Jason Gonzalez, and Caroline May Poor of Lawson Huck Gonzalez, PLLC, Tallahassee, Florida, for Interested Party, Susan B. Anthony Pro-Life America Jeremy D. Bailie and R. Quincy Bird of Weber, Crabb & Wein, P.A., St. Petersburg, Florida, for Interested Party, National Center for Life and Liberty Quinn Yeargain of Widener University Commonwealth Law School, Harrisburg, Pennsylvania; and Mark Dorosin of Florida A&M University College of Law, Orlando, Florida, for Interested Parties, Law Professors & Instructors Joshua A. Rosenthal and Aadika Singh of Public Rights Project, Oakland, California; and Matthew A. Goldberger of Matthew A. Goldberger, P.A., West Palm Beach, Florida, for Interested Parties, Current and Former Florida Republican Elected Officials Kelly O'Keefe and Hannah Murphy of Stearns Weaver Miller Weissler Alhadeff & Sitterson, P.A., Tallahassee, Florida, and Abby G. Corbett and Jenea E. Reed of Stearns Weaver Miller Weissler Alhadeff & Sitterson, P.A., Miami, Florida; Stephen Petkis, Judy Baho, Kendall J. Christie, and Aubrey Stoddard of Covington & Burling LLP, Washington, District of Columbia; Isaac D. Chaput of - 80 -

Covington & Burling LLP, San Francisco, California; and Vanessa J. Lauber of Covington & Burling LLP, New York, New York, for Interested Parties, Florida Doctors Michelle Morton, Daniel B. Tilley, and Nicholas Warren of American Civil Liberties Union Foundation of Florida, Miami, Florida; and Courtney Brewer, Tallahassee, Florida, for Interested Party, Floridians Protecting Freedom Carrie Flaxman and Skye Perryman of Democracy Forward Foundation, Washington, District of Columbia; and Sean Shaw of Swope, Rodante P.A., Tampa, Florida, for Interested Party, American College of Obstetricians and Gynecologists - 81

Home — Essay Samples — Education — School Uniform — Issue of Wearing School Uniforms: Bullying of Students’ Individuality

Issue of Wearing School Uniforms: Bullying of Students' Individuality

• Categories: School Uniform Student

About this sample

Words: 492 |

Published: Mar 1, 2019

Words: 492 | Page: 1 | 3 min read

Table of contents

School uniforms essay outline, school uniforms essay example, introduction.

• Introduction to the debate on whether students should wear uniforms
• Mention of the reasons for and against school uniforms

Security Concerns

• Discussion of the role of uniforms in enhancing school security
• Potential risks of allowing students to wear non-uniform clothing
• The issue of concealing weapons and identifying strangers

Bullying and Behavior Issues

• Exploration of how uniforms can prevent conflicts related to clothing
• The impact of uniforms on reducing behavioral problems
• The message sent to students about rules and consequences

Academic Focus

• Discussion of how uniforms can eliminate distractions related to clothing trends
• The idea that students may focus better on learning without clothing concerns
• The allocation of resources and time to address clothing-related issues

Individuality and Expression

• Examining the argument that uniforms restrict students' individuality
• How students may seek alternative means of expression, such as jewelry
• The debate over allowing jewelry and its impact on uniform policies
• Summarization of the main points discussed in the essay
• A balanced perspective on the benefits and drawbacks of school uniforms
• The role of uniforms in maintaining a well-structured school environment

Works Cited

• Brunsma, D. L., & Rockquemore, K. A. (1998). Effects of student uniforms on attendance, behavior problems, substance use, and academic achievement. The Journal of Educational Research, 92(1), 53-62.
• Bodine, A. (2003). School uniforms and the First Amendment. Education and the Law, 15(2), 169-178.
• Henning, E., & Slater, C. (2008). The effect of school uniforms on student achievement and behavior. Canadian Journal of Education, 31(2), 581-605.
• Brunsma, D. L. (2007). The school uniform movement and what it tells us about American education: A symbolic crusade. Rowman & Littlefield Education.
• King, N. (2013). Why we should get rid of school uniforms. The Atlantic. Retrieved from https://www.theatlantic.com/education/archive/2013/09/why-we-should-get-rid-of-school-uniforms/279801/
• Wong, W. (2009). The effectiveness of school uniforms on students' academic achievement and discipline. American Journal of Education, 116(4), 657-682.
• Bodine, A., & Provenzo, E. F. (2002). School uniforms: A qualitative analysis of aims and accomplishments. Journal of School Violence, 1(2), 47-63.
• Brunsma, D. L. (2006). School uniforms in America: A historical case study examining policy making and implementation. The Journal of Educational Thought, 40(3), 241-255.
• Cohen, S., & Smerdon, B. (2009). Do school uniforms make a difference? National Center for Education Statistics.
• Lumsden, L. S., Miller, M., & McBroom, W. H. (2009). School uniforms and the public schools: A decade of research and debate. Education and Urban Society, 41(3), 323-342.

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Why were so many metro stations in Moscow renamed?

Okhotny Ryad station in Soviet times and today.

The Moscow metro system has 275 stations, and 28 of them have been renamed at some point or other—and several times in some cases. Most of these are the oldest stations, which opened in 1935.

The politics of place names

The first station to change its name was Ulitsa Kominterna (Comintern Street). The Comintern was an international communist organization that ceased to exist in 1943, and after the war Moscow authorities decided to call the street named after it something else. In 1946, the station was renamed Kalininskaya. Then for several days in 1990, the station was called Vozdvizhenka, before eventually settling on Aleksandrovsky Sad, which is what it is called today.

The banner on the entraince reads: "Kalininskaya station." Now it's Alexandrovsky Sad.

Until 1957, Kropotkinskaya station was called Dvorets Sovetov ( Palace of Soviets ). There were plans to build a monumental Stalinist high-rise on the site of the nearby Cathedral of Christ the Saviour , which had been demolished. However, the project never got off the ground, and after Stalin's death the station was named after Kropotkinskaya Street, which passes above it.

Dvorets Sovetov station, 1935. Letters on the entrance: "Metro after Kaganovich."

Of course, politics was the main reason for changing station names. Initially, the Moscow Metro itself was named after Lazar Kaganovich, Joseph Stalin’s right-hand man. Kaganovich supervised the construction of the first metro line and was in charge of drawing up a master plan for reconstructing Moscow as the "capital of the proletariat."

In 1955, under Nikita Khrushchev's rule and during the denunciation of Stalin's personality cult, the Moscow Metro was named in honor of Vladimir Lenin.

Kropotkinskaya station, our days. Letters on the entrance: "Metropolitan after Lenin."

New Metro stations that have been opened since the collapse of the Soviet Union simply say "Moscow Metro," although the metro's affiliation with Vladimir Lenin has never officially been dropped.

Zyablikovo station. On the entrance, there are no more signs that the metro is named after Lenin.

Stations that bore the names of Stalin's associates were also renamed under Khrushchev. Additionally, some stations were named after a neighborhood or street and if these underwent name changes, the stations themselves had to be renamed as well.

Until 1961 the Moscow Metro had a Stalinskaya station that was adorned by a five-meter statue of the supreme leader. It is now called Semyonovskaya station.

Left: Stalinskaya station. Right: Now it's Semyonovskaya.

The biggest wholesale renaming of stations took place in 1990, when Moscow’s government decided to get rid of Soviet names. Overnight, 11 metro stations named after revolutionaries were given new names. Shcherbakovskaya became Alekseyevskaya, Gorkovskaya became Tverskaya, Ploshchad Nogina became Kitay-Gorod and Kirovskaya turned into Chistye Prudy. This seriously confused passengers, to put it mildly, and some older Muscovites still call Lubyanka station Dzerzhinskaya for old times' sake.

At the same time, certain stations have held onto their Soviet names. Marksistskaya and Kropotkinskaya, for instance, although there were plans to rename them too at one point.

"I still sometimes mix up Teatralnaya and Tverskaya stations,” one Moscow resident recalls .

 “Both have been renamed and both start with a ‘T.’ Vykhino still grates on the ear and, when in 1991 on the last day of my final year at school, we went to Kitay-Gorod to go on the river cruise boats, my classmates couldn’t believe that a station with that name existed."

The city government submitted a station name change for public discussion for the first time in 2015. The station in question was Voykovskaya, whose name derives from the revolutionary figure Pyotr Voykov. In the end, city residents voted against the name change, evidently not out of any affection for Voykov personally, but mainly because that was the name they were used to.

What stations changed their name most frequently?

Some stations have changed names three times. Apart from the above-mentioned Aleksandrovsky Sad (Ulitsa Kominterna->Kalininskaya->Vozdvizhenka->Aleksandrovsky Sad), a similar fate befell Partizanskaya station in the east of Moscow. Opened in 1944, it initially bore the ridiculously long name Izmaylovsky PKiO im. Stalina (Izmaylovsky Park of Culture and Rest Named After Stalin). In 1947, the station was renamed and simplified for convenience to Izmaylovskaya. Then in 1963 it was renamed yet again—this time to Izmaylovsky Park, having "donated" its previous name to the next station on the line. And in 2005 it was rechristened Partizanskaya to mark the 60th anniversary of victory in World War II. 

Partizanskaya metro station, nowadays.

Another interesting story involves Alekseyevskaya metro station. This name was originally proposed for the station, which opened in 1958, since a village with this name had been located here. It was then decided to call the station Shcherbakovskaya in honor of Aleksandr Shcherbakov, a politician who had been an associate of Stalin. Nikita Khrushchev had strained relations with Shcherbakov, however, and when he got word of it literally a few days before the station opening the builders had to hastily change all the signs. It ended up with the concise and politically correct name of Mir (Peace).

The name Shcherbakovskaya was restored in 1966 after Khrushchev's fall from power. It then became Alekseyevskaya in 1990.

Alekseyevskaya metro station.

But the station that holds the record for the most name changes is Okhotny Ryad, which opened in 1935 on the site of a cluster of market shops. When the metro system was renamed in honor of Lenin in 1955, this station was renamed after Kaganovich by way of compensation. The name lasted just two years though because in 1957 Kaganovich fell out of favor with Khrushchev, and the previous name was returned. But in 1961 it was rechristened yet again, this time in honor of Prospekt Marksa, which had just been built nearby.

Okhotny Ryad station in 1954 and Prospekt Marksa in 1986.

In 1990, two historical street names—Teatralny Proyezd and Mokhovaya Street—were revived to replace Prospekt Marksa, and the station once again became Okhotny Ryad.

Okhotny Ryad in 2020.

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Pulling together: how Cambridge came to dominate the Boat Race – a photo essay

The race along the River Thames between England’s two greatest universities spans 195 years of rivalry and is now one of the world’s oldest and most famous amateur sporting events. Our photographer has been spending time with the Cambridge University Boat Club over the past few months as they prepare for 2024’s races

T he idea of a Boat Race between the two universities dates back to 1829, sparked into life by a conversation between Old Harrovian schoolfriends Charles Merivale, a student at the time at St John’s College Cambridge, and Charles Wordsworth who was at Christ Church Oxford. On 12 March that year, following a meeting of the newly formed Cambridge University Boat Club, a letter was sent to Oxford.

The University of Cambridge hereby challenge the University of Oxford to row a match at or near London each in an eight-oar boat during the Easter vacation.

From then, the Cambridge University Boat Club has existed to win just one race against just one opponent, something Cambridge has got very good at recently. Last year the Light Blues won every race: the open-weight men’s and women’s races, both reserve races, plus both lightweight races – six victories, no losses, an unprecedented clean sweep. Cambridge women’s open-weight boat, or blue boat, has won the last six Boat Races while the men’s equivalent have won five out of the last seven. In such an unpredictable race, where external factors can play a large part, this dominance is startling.

Thames trials

Rough water as the two women’s boats make their way along the River Thames near Putney Embankment during the Cambridge University Boat Race trials.

It’s a mid-December day by the River Thames. The sky and water merge together in a uniform battleship grey and the bitter north wind whips the tops off the waves. Outside a Putney boathouse two groups of tense-looking women dressed in duck-egg blue tops and black leggings with festive antlers in their hair are huddling together, perhaps for warmth, maybe for solidarity. The odd nervous bout of laughter breaks out. For some of them this is about to be their first experience of rowing on the Tideway, a baptism of fire on the famous stretch of London water where the Boat Race takes place. “Perfect conditions,” remarks Paddy Ryan, the head coach for Cambridge University women, for this is trial eights day, when friends in different boats duel for coveted spots in the top boat.

A couple of hours later these women along with their male equivalents will have pushed themselves to the absolute limit, so much so that several of the men are seen trying to throw up over the side of their boats at the finish under Chiswick Bridge. This may be brutal but it’s just the start. For these students the next few months are going to be incredibly tough, balancing academic work with training like a professional athlete. Through the harshest months of the year they will be focused on preparing for the end of March and a very simple goal: beating Oxford in the Boat Race.

Agony for one of the men’s boats after the finish of the race near Chiswick Bridge during the Cambridge University Boat Race trials.

Ely early mornings

Two of the women’s boats head out in the early morning for a training session on the Great Ouse.

Early winter mornings on the banks of the Great Ouse, well before the sun has risen, can be pretty bleak. In the pitch black a batch of light blue minivans drop off the men and women rowers together at the sleek Ely boathouse that was opened in 2016 at the cost of £4.9m – it’s here that all Cambridge’s on-water training takes place. Very soon a fleet of boats carrying all the teams takes to the water for a training session that may last a couple of hours. Then it’s a quick change, a lift to the train station and back to Cambridge for morning lectures.

The women’s squad head into the Ely boathouse after a 6am drop-off.

As a rower descends the stairs to the bays where the boats are stored, there is a clear indication of why it was built and why they are there. “This is where we prepare to win Boat Races,” a sign says. Since this boathouse was built, Cambridge have won 30 of the 37 races across all categories.

Top: The men’s squad stretch in the boathouse before an early morning training session and a member of the men’s blue boat descends the stairs into where the boats are kept. Below: One of the men’s teams set off for early morning training and the women’s blue boat rows past the women’s lightweight crew during a training session.

It’s a far cry from the old tin sheds with barely any heating and no showers. These current facilities are impressive, enabling the entire men’s and women’s squads to be there at the same time and get boats out.

Top: The men’s blue boat prepare to derig their boat at their Ely training site. Above: The women’s blue boat put their vessel back in the boathouse after a training session on the Great Ouse.

But it’s not just the boathouse that has contributed so much, it’s also the stretch of water they train on. In a year when floods have affected so many parts of the country it has really come into its own. Paddy Ryan, the chief women’s coach, explains: “Along this stretch the river is actually higher than the surrounding land. The water levels are carefully managed by dikes and pumps. As a result we haven’t lost a single session to flooding. That’s not the case for Oxford. I believe their boathouse has been flooded multiple times this year, unable to get to their boats. We’ve had multiple storms but we’ve been able to row through them all.”

The men’s third boat practises on the Great Ouse.

It’s a flat, unforgiving landscape, especially in midwinter, definitely not the prettiest stretch of water, but Cambridge don’t care. Ryan says: “It might be a little dull on the viewing perspective but we could row on for 27km before needing to turn round. We have a 5km stretch that is marked out every 250m. We are lucky to have it.”

The men’s blue boat practise their starts on the long straight on the Great Ouse.

The sweat box

Members of the men’s squad check on their technique with the use of a mirror at the Goldie boathouse.

The old-fashioned Goldie boathouse is right in the centre of Cambridge perched on the banks of the River Cam. Built in 1873, its delicate exterior belies what goes on inside. This is the boat club’s pain cave, where the rowers sweat buckets, pushing themselves over and over again; it’s a good job the floor is rubberised and easy to wipe clean.

A wreath to Charles Merivale, the founder of the Boat Race, and wood panelling in the upstairs room at the Goldie boathouse which commemorates Cambridge crews that have competed in the Boat Race from 1829.

(Top) Seb Benzecry, men’s president of the Cambridge University Boat Club, and (above) Martin Amethier, a member of the reserve Goldie crew, sweat during sessions on ergo machines.

Iris Powell of the women’s blue boat (above) performs pull-ups during a training session.

Above left: Hannah Murphy, the cox of the women’s blue boat, urges on four of her crew (left to right) Gemma King, Megan Lee, Jenna Armstrong and Clare Hole, as they undertake a long session on the ergo machines. Above right: Kenny Coplan, a member of the men’s blue boat crew, looks exhausted then writes in his times after his session on an ergo machine (below).

Brutal sessions on the various ergo machines, where thousands of metres are clocked and recorded, are a staple of the training regime set in place. If there is any slacking off the students just need to look up at one of the walls where a map of the Boat Race course hangs. The “S” shape of the Thames has been carefully coloured in the correct shade of blue and record timings for various key points on the course have been written in for both men and women. All but one record, and that one is shared, is held by Cambridge.

Paddy Ryan, the women’s chief coach, talks to the women’s blue boat during a training session on the River Great Ouse in February.

A key ingredient in any successful team is the coaching. Cambridge’s setup is stable and well established. Paddy Ryan is the chief women’s coach, a genial, tall Australian, he has been part of the women’s coaching team since 2013. The care and devotion to his squad is perfectly clear. “I have my notebook next to my bed so I can jot things down. I wake up in the middle of the night going: am I making the right decisions? I care about them as people and I need to manage them … We joke as coaches that we are teaching some of the smartest people on the planet how to pull on a stick.”

Rob Baker, the chief men’s coach, has Cambridge rowing in the blood. Born and bred in the city, his father was a university boatman for 25 years. He even married into the sport – his wife, Hayley, rowed for Cambridge as a lightweight – so it was no surprise that he became part of the coaching setup way back in 2001. He was the first full-time women’s coach in 2015 then moved to take over the men in 2018.

Rob Baker, the men’s chief coach, talks to his blue boat at their Ely training site.

Apart from an obvious role in the development of rowing skills, a key part of their job is making sure there is a balance for their student athletes. They understand they have to juggle training needs. “Every week we have a general plan,” says Baker, “but then someone might have an extra class or supervision they’ve got to do so we have to move around it. They are studying at one of the most competitive universities in the world with the highest standards so you’ve got to give them space to do that properly.” He goes on: “But when they get on the start line for their race, they’ll be just as competitive as if they were professionals.”

The presidents

Jenna Armstrong and Seb Benzecry discuss their plans in the Great Hall at Jesus College.

Every year one man and one woman are elected presidents to represent Cambridge University Boat Club. They are the captains and leaders, not only responsible for helping design the training programme in conjunction with the coaches but also making budgetary and tactical decisions along the way. This year both of them, Jenna Armstrong and Seb Benzecry, are from the same college, Jesus, which helps the communication between the two of them. They share ideas and knowledge, thoughts and worries. Their lives, for these intense few months, are a juggling act.

Armstrong is a 30-year-old from New Jersey, and doing a PhD in physiology. Once a very keen competitive junior skier she was forced to abandon her hopes of a career on the slopes after a number of serious knee injuries. She only started rowing in 2011 and only became aware of the Boat Race when she saw it on TV a couple of years later.

Jenna Armstrong, cycling down the Chimney, the grand entrance to Jesus College, to go to the other side of the city to carry out more of her PhD research at the department of physiology, development and neuroscience.

The research she carries out at the university labs could be turn out to be life-saving. “I study mitochondrial function in placentas from women from all over the world to learn how genetic and environmental factors during pregnancy can influence placental metabolism and impact the health of both mother and baby. I’m particularly interested in growth restriction which affects about 10% of babies worldwide. That can have lifelong implications for these babies and currently we don’t have any treatment for this.”

Benzecry, 27, is studying for a PhD in film and screen studies, and comes from a completely different rowing background. He grew up just a stone’s throw from the Boat Race course and went to a school on the banks of the Thames. This will be his 14th year of competitive rowing but his fourth and last Boat Race.

“ I remember one year my birthday fell on race day and we watched after my birthday party. Because we live fairly close to the course, I’ve always felt connected to the race.”

Seb Benzecry stands next to an Antony Gormley statue in the Quincentenary Library at Jesus College as he conducts research for his dissertation which forms part of his PhD in film and screen studies.

Talking about how hard it is to get the right balance between academic student life and rowing, Benzecry says: “I guess you have to accept there are many, many things you can’t do, you just don’t have time for during the season. You have to put the blinkers on.”

Armstrong says: “I have to be very prepared, very strategic and organised. I pack everything the night before, and then once I leave my room in the morning, I don’t go back. That allows me to go to training, go to the lab, go to training again. It’s surreal actually, to come to a place like Cambridge, have one of the best educations in the world on top of the most incredible rowing experiences in the world. We have a thing now in the boat, when we are doing something incredibly hard, I say this is my ideal Saturday, I wouldn’t want to be anywhere else. I would rather be here than in bed or on a date. And I make everyone else say it with me too. I’d rather be nowhere else.”

Benzecry states: “When it’s really bad, when training is so hard, we say Oxford aren’t doing this, they could never do this. It’s an incredibly powerful thing to be thinking we work harder than them, our culture is better than them. They don’t want to go hard as we do – they might think they do but they don’t, they just don’t have it.”

Integration

The men’s and women’s blue boats during a training session on the River Great Ouse in February.

Until 1 August 2020, there were three separate university boat clubs in Cambridge: one for open-weight men, one for lightweight men, and one for open-weight and lightweight women. Since they merged to become one club, it has undoubtedly helped with everyone sharing the same resources and motivating and inspiring one another. No one is more important and everyone has a key part to play in the result. This year, Oxford have followed suit.

Baker says: “I definitely feel, for the athletes themselves, it makes a big difference. They all feel like they’re contributing to one common goal. Every cog in the wheel has to do its job but for sure it feels like one big team on a mission.”

Benzecry explains: “We’re seeing each other train, we’re all out on the water at the same time, we’re supporting each other throughout the season, building a sense of momentum for the whole club towards the races. Everyone’s just inspiring each other all the time and I think that’s been such a sort of cultural shift for Cambridge.”

The men’s blue boat pack their craft on to a trailer at their Ely training site ready for the trip down to London for the Boat Race.

Siobhan Cassidy, the chair of the Boat Race, knows from first-hand how the integration has helped. She rowed for the Light Blues in 1995 and had a key role in the transition. “We could see the advantages of working together, collaborating as a bigger team, the positive impact we felt that could have on performance. But not just the output, actually the whole experience for the young people taking part.”

Siobhan Cassidy, the chair of the Boat Race, pictured at the Thames Rowing Club at Putney Embankment.

This Saturday, if the weather holds, an estimated 250,000 people, the vast majority of whom have no allegiance to one shade of blue or the other, will pack the banks of the Thames to see these races. It’s one of the largest free events in Britain. Broadcast live on BBC One, the race is also beamed to 200 countries across the world.

The starting stone for the University Boat Race and pavement inscription: “The best leveller is the river we have in common” at Putney Embankment.

A map of the Boat Race course at the Goldie boathouse, with the Thames coloured in Cambridge blue and record timings written in for men and women showing almost total Cambridge dominance.

A sporting pinnacle being contested on a fast-flowing, unpredictable river by two teams of university students – it’s pretty bizarre. But maybe it’s that quirkiness that keeps the race, after almost two hundred years, still going strong. And even more bizarre to think that Cambridge, the current dominant force in the Boat Race, a sporting event that can’t shrug off its elitist stereotype, owes so much of that success to such egalitarian principles.

• The Guardian picture essay
• The Boat Race
• University of Cambridge
• Photography

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