Paradox of Self-Amendment by Peter Suber 1.B) in a state constitutional convention that happened to be in session. When the 1870 constitution was ratified, four important articles of it were voted upon separately. One forbade "legislative or other authority" to release, remit, suspend or alter obligations of the Illinois Central Railroad to the State of Illinois. If the unqualified language of this prohibition reached the amendment power, which was never tested in court, then the unnumbered article was a (revocable) limit on the 1870 AC, although not a product of self-amendment. Indiana Current constitution: 1851 AC: Article 16 Prior constitutions: 1816 AC: Article 8 AC amended? Yes. AC §2 was amended November 8, 1966. Comment. Article 1, §1 of the Indiana Bill of Rights recognizes that "the people have, at all times, an indefeasible right to alter and reform their government." Iowa Current constitution: 1857 AC: Article 10 Prior constitutions: 1846 AC: Article 10 AC amended? Yes. AC §3 was amended in 1964. Comment. In 1920 the voters overwhelmingly approved a call for a constitutional convention. The legislature violated a mandatory provision of the constitution (AC §3) by failing to call the convention. Neither the courts nor the people imposed sanctions on the legislators, and no constitutional convention has been called since. Article 1, §2 of the Iowa Bill of Rights asserts that the people have "the right, at all times, to alter or reform [their government] whenever the public good may require it." Kansas Current constitution: 1859 AC: Article 14 Prior constitutions: none AC amended? Yes. Entire AC repealed and replaced, November 3, 1970. Comment. For a case holding that the amendment of the AC above is valid because properly submitted pursuant to the old AC, see Moore v. Shanahan, 207 K. 1, 207 K. 645, 486 P.2d 506 (1971). Kentucky Current constitution: 1891 AC: §§256-63 Prior constitutions: 1850 AC: Article 12 1799 AC: Article 9 1792 AC: Article 11 AC amended? No. Comment. Section 4 of the Kentucky Bill of Rights declares that the people "have at all times an inalienable and indefeasible right to alter, reform or abolish their government in such manner as they may deem proper." Louisiana Current constitution: 1974 AC: Article 13 Prior constitutions: 1921 AC: Article 21 1913 AC: Article 325 1898 AC: Articles 321-24 1879 AC: Article 256 1868 AC: Article 147 1864 AC: Article 147 1852 AC: Article 141 1845 AC: Article 140 1812 AC: Article 7 AC amended? No. Comment. At least the 1913 and 1921 constitutions were not made under the authority of the prior ACs. The 1898 constitution contained no provision for revision by convention, and was revised (into the 1913 constitution) under a call by the legislature. State v. American Sugar Refining Co., 137 La. 407, 68 So. 742 (1915). Maine Current constitution: 1819 AC: Article 10, §4 Prior constitutions: none 181