With certain constitutional limitations, the Legislature may place conditions on the receipt of appropriations. See Lewis v State, 352 Mich. 422, 430; 90 N.W.2d 856 (1958); Bd of Agriculture v Auditor General, 226 Mich. 417, 425; 197 N.W. 160 (1924); Kalamazoo, supra at 572. When an appropriation made subject to a constitutionally valid condition is accepted, the condition becomes binding on the party receiving the appropriation.
It does not create an unconstitutional, separate object because this condition is germane to the appropriation. Lewis v State, 352 Mich. 422, 429; 90 N.W.2d 856 (1958). The Title-Object Clause is "only violated where the subjects are so diverse in nature that they have no necessary connection."
Further, the panel reasoned that if Providers are successful, the constitutional principles established by the case "could bar the General Assembly from โtieing legislative stringsโ to its appropriation of funds for the Medical Assistance program." Id. at 912 (quoting Lewis v. State, 352 Mich. 422, 90 N.W.2d 856, 860 (1958)). According to the panel, the litigation could impact Intervenorsโ constitutional authority to control the Commonwealthโs finances.
In the absence of specific legislation setting rates of pay, the trial court was correct in holding PA 1909, No 84, ยง 45, applied. Lewis v. State (1958), 352 Mich. 422, dealing with pensions, and Wayne County v. Social Welfare Department (1955), 343 Mich. 475, relating to state hospital patients, cited by defendants, are distinguishable and not controlling. The appropriating statutes in the present case did not refer to or set any standard for payment of state military officers.
The tieing of legislative strings to appropriation of state funds for governmental purposes has never been considered as adding a second object to an appropriation law[.] Lewis v. State , 352 Mich. 422, 90 N.W.2d 856, 860 (1958) (quoting an opinion of the Michigan Attorney General).
This is the case in other jurisdictions as well. See, e.g., State ex rel. Whittier v. Safford, 214 P. 759 (N.M. 1923) (wherein the court held that details such as the per diem travel expenditures allowed state officials was a "detail" properly included in a general appropriations act); Lewis v. State, 90 N.W.2d 856 (Mich. 1958) (wherein the court held that reducing the retirement pay of an officer of the Michigan National Guard by amounts received from the U.S. government was found not to add a second object to an appropriation of state funds); Schuyler v. South Mall Constructors, 303 N.Y.S.2d 901 (N.Y.App.Div. 1969) (wherein the court held that authorizing the Commissioner of General Services to negotiate a contract for the construction of a state library and museum was not "general legislation" and, thus, could be included in the appropriations act). This is not to say that challenges to an appropriations act for violating a constitutional provision similar to Pennsylvania's Article III, Section 11, cannot succeed.