Article IV, Section 9 of the California Constitution provides "A statute shall embrace but one subject, which shall be expressed in its title". This rather simple notion, absent from the United States Constitution, dates back over two millenia to the Roman Republic. In 98 B.C.E., two consuls, Quintus Caecilius Metellus Nepos and Titus Didius fathered the enactment of the eponymous Lex Caecilia Didia. Like its modern counterpart, the Lex Caecilia Didia prohibits a lex satura, or stuffed law. The second century Roman grammarian Sextus Pompeius Festus described a "stuffed law" as a "lex multis aliis conferta legibus" or a law crowded with many others. The great Roman lawyer Marcus Tullius Cicero described the Lex Caecilia Didia as follows in his Oratio de Domo Sua:

Quae est, queso, alia vis, qua sententia Caecilia Legis et Didiae nisi hae, ne populo necesse sit in coniunctis rebus compluribus aut quod nolit accipere aut id quod velit repudiare? (What is, I ask, other than this, is the meaning of the law of Caecilius and Didius except this, that the people by many different conjoined things to accept what they are unwilling to accept or which they wish to repudiate?

The evil of stuffed laws are they prevent a legislative body from considering laws governing diverse subjects on their own merits and fosters obfuscation. A stuffed law may also enable lawmakers to engineer majority votes by combining different measures supported by different constituencies.