The Colorado Supreme Court has ruled that Initiative 16—a proposed ballot initiative which would have eliminated some exemptions in the state’s criminal animal cruelty statutes and expanded the definition of “sexual act with an animal”—violates the state constitution’s single-subject requirement. In overruling the state Title Board, the court held that while the central theme of the initiative was “incorporating livestock into the animal cruelty statutes,” because the sexual act criminal expansion applied to animals other than livestock, the measure failed the single-subject requirement.