[323]*323O’Donnell, J.
{¶ 1} LetOhioVote.org, a ballot-issue committee, and Thomas E. Brinkman Jr., David Hansen, and Gene Pierce, Ohio resident-electors and members of LetOhioVote.org, filed this original action seeking a writ of mandamus to compel the secretary of state to treat the video-lottery-terminal (“VLT”) provisions of 2009 Am.Sub.H.B. No. 1 (“H.B. 1”) as subject to referendum and to discharge her duties pursuant to Article II of the Ohio Constitution and R.C. Chapter 3519. The narrow focus of this case excludes policy considerations, which are the province of the legislative and executive branches, and is singularly centered on whether the citizens of Ohio have the right of referendum on the VLT provisions of H.B. 1, which authorize the Ohio Lottery Commission to locate as many as 2,500 VLTs at each of Ohio’s seven horse-racing tracks for a potential of 17,500 machines in Ohio. The legal issue before us is whether these VLT provisions of H.B. 1 are an appropriation for the current expenses of the state government and are therefore not subject to referendum pursuant to Section Id, Article II of the Ohio Constitution. After careful review of this important question, we conclude that our jurisdiction has been properly invoked, that mandamus is an appropriate remedy, and that the VLT provisions of H.B. 1 are subject to referendum. Because relators have established entitlement to the requested extraordinary relief, we grant the writ and direct the secretary of state to treat the VLT provisions of H.B. 1 as subject to referendum.
Facts and Procedural Background
{¶ 2} On July 13, 2009, Governor Strickland issued a directive to the Ohio Lottery entitled “Implementing Video Lottery Terminals.” In particular, the governor directed the Ohio Lottery Commission to immediately take steps to implement the placement of as many as 2,500 VLTs at each of seven horse-racing tracks in Ohio upon acknowledgement by the General Assembly of the commission’s authority to do so. However, the governor expressly conditioned the implementation of the directive upon the passage of the VLT provisions by the General Assembly, explaining that if the provisions were not enacted “into law as part of or prior to the FY10-11 biennial budget law and such law is not signed into law by [the governor] within five days of the issuance of this Directive, the Directive shall then be deemed immediately null and void.”
[324]*324H.B. 1
{¶ 3} On the same day that the governor issued his VLT directive, the General Assembly enacted H.B. 1, which includes the 2010-2011 biennial budget. H.B. 1 provides a line-item appropriation from the Lottery Profits Education Fund of over $2.2 billion to the Department of Education, which increases the appropriation to the Department of Education for Foundation Funding Fund from this fund for the current biennium by $851.5 million to reflect the expected revenues from the implementation of VLTs in May 2010 and the associated license fees. H.B. 1 also includes amendments to R.C. Chapter 3770 that authorize the State Lottery Commission to operate VLT games and promulgate rules relating to the commission’s operation of VLT games, that specify that the provisions of R.C. Chapter 2915 criminalizing gambling activities are inapplicable, that bar political subdivisions from assessing new license or excise taxes on VLT licensees, and that purport to vest this court with exclusive, original jurisdiction over any claim that the provisions are unconstitutional.1
[325]*325{¶ 4} In enacting H.B. 1, the General Assembly declared that the amendments relating to VLTs — R.C. 3770.03 and 3770.21 — are exempt from referendum because “[they are] or relate[ ] to an appropriation for current expenses within the meaning of Ohio Constitution, Article II, Section Id and section 1.471 of the Revised Code, * * * and therefore take[] effect immediately when this act becomes law.” Section 812.20 of H.B. 1. H.B. 1 additionally indicates that certain other amendments are subject to referendum and will not become immediately effective. Sections 812.10, 812.30, and 812.50 of H.B. 1.
{¶ 5} The governor signed H.B. 1 into law on July 17, 2009.
Mandamus Case
{¶ 6} On July 20, 2009, relators filed this action seeking a writ of mandamus to compel respondent, Secretary of State Jennifer Brunner, to treat the VLT provisions of H.B. 1 as subject to referendum. We issued an accelerated briefing schedule and granted the motion of the directors of the Office of Budget and Management and the Ohio Lottery Commission to intervene as additional respondents (“intervening respondents”).
{¶ 7} On July 23, 2009, relators presented for filing with the secretary of state a referendum-petition summary, consisting of numerous part-petitions containing over 3,000 signatures, and a copy of one of the summary part-petitions for filing with the office of the attorney general. The office of the secretary of state deferred to the General Assembly’s declaration that the VLT sections of H.B. 1 are not subject to referendum and declined to accept the filing of the referendum petitions “[i]n the absence of a court order to the contrary.” The office of the attorney general similarly rejected the filing presented to it, based on the conclusion that the VLT provisions were not subject to referendum.
{¶ 8} The rejection of the proffered filings precluded relators from circulating the referendum petition for signatures. Relators sought, and we granted, leave [326]*326to file an amended complaint that included the events that took place after the original complaint was filed.
{¶ 9} In briefs and arguments before this court, relators contend that the VLT provisions are subject to referendum because they are not appropriations for current state expenses, they neither make expenditures nor incur obligations, and they are not temporary measures necessary to effectuate an appropriation; instead, relators argue, the VLT provisions constitute a change in the permanent law of this state that generates, rather than spends, money, and they seek a 90-day stay of the VLT provisions so that they may have a meaningful opportunity to circulate a referendum petition.
{¶ 10} The secretary of state urges that she does not have a clear legal duty to disregard the General Assembly’s declaration in the bill that the VLT provisions are not subject to referendum or to adjudicate the question of whether the VLT provisions constitute an appropriation for current state expenses exempt from referendum. Instead, she maintains that she has a duty to reject referendum petitions that do not comply with express provisions of law and suggests that relators have an adequate remedy at law by way of an action for a declaratory judgment and an injunction in the common pleas court. She also contends that relators are merely seeking a declaratory judgment and an injunction, which this court lacks jurisdiction to issue.
{¶ 11} Intervening respondents contend that the VLT provisions are not subject to referendum, because they appropriate money for education. However, to the extent that the VLT provisions themselves are not direct appropriations, the intervening respondents argue that the referendum process does not apply to laws providing for appropriations for current state expenses or to laws that are “inextricably tied” to a line-item appropriation for the current expenses of the state government or state institutions. Thus, intervening respondents claim that the VLT provisions provide for, or are inextricably tied to, the line-item appropriation for education in H.B. 1 because the VLT provisions generate the revenue that funds the appropriation. Further, without the VLT provisions, the appropriation cannot become immediately effective as required by Section Id, Article II, of the Ohio Constitution. Lastly, the intervening respondents contend that granting a writ of mandamus would be a vain act because the Lottery Commission already possesses the authority to implement VLT gaming without the amendments enacted by H.B. 1.
{¶ 12} Accordingly, we are called on to address whether relators are entitled to a writ of mandamus to compel the secretary of state to treat the VLT provisions of H.B. 1 as subject to referendum.
[327]*327Mandamus
{¶ 13} To be entitled to a writ of mandamus, “relators must establish a clear legal right to the requested relief, a corresponding clear legal duty on the part of the secretary of state to provide it, and the lack of an adequate remedy in the ordinary course of the law.” State ex rel. Heffelfinger v. Brunner, 116 Ohio St.3d 172, 2007-Ohio-5838, 876 N.E.2d 1231, ¶ 13. Mandamus is available to challenge the failure to certify a referendum-petition summary. Cf. State ex rel. Barren v. Brown (1977), 51 Ohio St.2d 169, 171, 5 O.O.3d 136, 365 N.E.2d 887 (writ of mandamus granted to compel attorney general to certify that the referendum-petition summary is a fair and truthful statement of the measure to be referred).
{¶ 14} Relators seek a writ of mandamus to compel the secretary of state to treat the VLT sections of H.B. 1 — R.C. 3770.03 and 3770.21 — as subject to the constitutional right of referendum and to fulfill each of her duties and obligations relating to the referendum under Article II of the Ohio Constitution and R.C. Chapter 3519. We conclude that relators’ complaint for a writ of mandamus properly invokes our original jurisdiction and that an action in the court of common pleas for a declaratory judgment or a prohibitory injunction would not provide an adequate remedy in the ordinary course of law.
{¶ 15} “In general, if declaratory judgment would not be a complete remedy unless coupled with extraordinary ancillary relief in the nature of a mandatory injunction, the availability of declaratory judgment does not preclude a writ of mandamus.” State ex rel. Mill Creek Metro. Park Dist. Bd. of Commrs. v. Tablack (1999), 86 Ohio St.3d 293, 297, 714 N.E.2d 917. In this case, a declaratory judgment would not be an adequate remedy without a mandatory injunction ordering the secretary of state to treat the VLT sections of H.B. 1 as subject to referendum. See State ex rel. Ohio Gen. Assembly v. Brunner, 114 Ohio St.3d 386, 2007-Ohio-3780, 872 N.E.2d 912, ¶ 25.
{¶ 16} Nor would a prohibitory injunction provide relators with the relief they request here: an order to compel the secretary of state to comply with her duties under Section 1c, Article II of the Ohio Constitution and R.C. 3519.01 to treat the VLT provisions as being subject to referendum. Moreover, given the state’s desire to immediately implement these provisions and relators’ wish to immediately begin the referendum process, a common pleas court action would not be sufficiently speedy to determine whether the VLT provisions of H.B. 1 are subject to referendum. See State ex rel. Beane v. Dayton, 112 Ohio St.3d 553, 2007-Ohio-811, 862 N.E.2d 97, ¶ 31 (“The alternate remedy must be complete, beneficial, and speedy in order to be an adequate remedy at law”).
{¶ 17} Therefore, relators lack an adequate remedy in the ordinary course of law to raise their claim, and mandamus is an appropriate remedy to resolve it.
[328]*328The Right of Referendum
{¶ 18} “The constitutional right of citizens to referendum is of paramount importance.” State ex rel. Ohio Gen. Assembly v. Brunner, 115 Ohio St.3d 103, 2007-Ohio-4460, 873 N.E.2d 1232, ¶ 8. “The referendum * * * is a means for direct political participation, allowing the people the final decision, amounting to a veto power, over enactments of representative bodies. The practice is designed to ‘give citizens a voice on questions of public policy.’ ” Eastlake v. Forest City Ents., Inc. (1976), 426 U.S. 668, 673, 96 S.Ct. 2358, 49 L.Ed.2d 132, quoting James v. Valtierra (1971), 402 U.S. 137, 141, 91 S.Ct. 1331, 28 L.Ed.2d 678.
{¶ 19} In 1912, the electors of Ohio adopted the initiative and referendum amendment to the constitution. Shortly thereafter, we explained the significance of the amendment:
{¶ 20} “Now, the people’s right to the use of the initiative and referendum is one of the most essential safeguards to representative government. * * * The potential virtue of the T. & R.’ does not reside in the good statutes and good constitutional amendments initiated, nor in the bad statutes and bad proposed constitutional amendments that are killed. Rather, the greatest efficiency of the T. and R.’ rests in the wholesome restraint imposed automatically upon the general assembly and the governor and the possibilities of that latent power when called into action by the voters.” State ex rel. Nolan v. ClenDening (1915), 93 Ohio St. 264, 277-278, 112 N.E. 1029.
{¶ 21} “This reserved power of referendum applies to every law passed in this state and provides an important check on actions taken by the government.” Ohio Gen. Assembly, 115 Ohio St.3d 103, 2007-Ohio-4460, 873 N.E.2d 1232, ¶ 9. Thus, “[l]aws generally do not take effect until 90 days have passed from the date they are filed by the governor with the secretary of state, to allow for a possible referendum. Section 1c, Article II, Ohio Constitution.” Id.
Exceptions to the Right of Referendum
{¶ 22} Section Id, Article II of the Ohio Constitution sets forth exceptions to the general rule that all laws and sections of laws are subject to referendum and thus do not become immediately effective:
{¶ 23} “Laws providing for tax levies, appropriations for the current expenses of the state government and state institutions, and emergency laws necessary for the immediate preservation of the public peace, health or safety, shall go into immediate effect. * * * The laws mentioned in this section shall not be subject to referendum.”
{¶ 24} In construing these exceptions, “we must ‘read words and phrases in context according to the rules of grammar and common usage.’ ” State ex rel. Colvin v. Brunner, 120 Ohio St.3d 110, 2008-Ohio-5041, 896 N.E.2d 979, ¶ 43, [329]*329quoting State ex rel. Lee v. Karnes, 103 Ohio St.3d 559, 2004-Ohio-5718, 817 N.E.2d 76, ¶ 23. We liberally construe the powers of initiative and referendum to effectuate the rights reserved. State ex rel. Evans v. Blackwell, 111 Ohio St.3d 1, 2006-Ohio-4334, 854 N.E.2d 1025, ¶ 32. Further, “[i]n view of the great precaution taken by the constitutional convention of 1912 to set forth and safeguard, with the particularity of detail usually found only in legislative acts, the right of referendum, and the three exceptions thereto, our court should not deny the people that right, unless the act in question is plainly and persuasively included within one of the three classes excepted from the operation of the referendum.” (Emphasis added.) State ex rel. Keller v. Forney (1923), 108 Ohio St. 463, 467-468, 141 N.E. 16. These exceptions to the general rule of referendum must be strictly, but reasonably, construed. Id. at paragraphs one and two of the syllabus.
The Language of the Exceptions
{¶ 25} The intervening respondents contend that the court should read the exception for appropriations to include “laws providing for” appropriations. We reject this contention. The language used in Section Id, Article II of the Ohio Constitution demonstrates that the phrase “Laws providing for” modifies only “tax levies.” Otherwise, Section Id would also provide an exception for “Laws providing for * * * emergency laws.” Further, to the extent that there are two reasonable interpretations of Section Id, our caselaw requires that we narrowly construe the exceptions to the right of referendum.
{¶ 26} The plain language of Section Id, Article II of the Ohio Constitution creates three categories of exceptions from referendum: (1) laws providing for tax levies, (2) appropriations for current expenses of the state government and state institutions, and (3) emergency laws necessary for the immediate preservation of the public peace, health, or safety. •
{¶ 27} Intervening respondents also contend either that the VLT provisions themselves are an appropriation or that when read in pari materia with the constitutional requirement that any funds raised by the state lottery can be used only to support education, this legislation is an appropriation. We do not agree.
{¶ 28} An appropriation is “an authorization granted by the general assembly to make expenditures and to incur obligations for specific purposes.” R.C. 131.01(F). Similarly, in State ex rel. Akron Edn. Assn. v. Essex (1976), 47 Ohio St.2d 47, 49, 1 O.O.3d 28, 351 N.E.2d 118, we explained that the ordinary and common meaning of the phrase “appropriation bill” is a “measure before a legislative body which authorizes ‘the expenditure of public moneys and stipulating the amount, manner, and purpose of the various items of expenditure.’ ” Id. at 49, 1 O.O.3d 28, 351 N.E.2d 118, quoting Webster’s New International Dictionary (2d Ed.). See also Black’s Law Dictionary (9th Ed.2009) 117-118 [330]*330(defining “appropriation” to mean “[a] legislative body’s act of setting aside a sum of money for a public purpose”).
{¶ 29} The VLT provisions of H.B. 1 are not themselves appropriations for state expenses because they do not set aside a sum of money for a public purpose; neither R.C. 3770.03 nor 3770.21 as amended by H.B. 1 makes expenditures or incurs obligations. Rather, they authorize the State Lottery Commission to operate VLT games and to promulgate rules relating to the commission’s operation of VLT games, specify that the provisions of R.C. Chapter 2915 criminalizing gambling activities are inapplicable, bar political subdivisions from assessing new license or excise taxes on VLT licensees, and purport to vest this court with exclusive, original jurisdiction over any claim that the provisions are unconstitutional.
{¶ 30} We reject intervening respondent’s position that because the funds generated by the VLTs must be used for education, the VLT provisions of H.B. 1 constitute an appropriation. Section 6, Article XV mandates that any funds raised by the state lottery be used to support education “as determined in appropriations made by the General Assembly.” The VLT provisions of H.B. 1 do not appropriate anything. A separate provision of H.B. 1 — line-item 200612 - appropriates these funds to education. Thus, notwithstanding the constitutional mandate that all lottery funds be spent on education, the existence of a separate line item for appropriation of the revenues generated by VLTs demonstrates that the VLT provisions themselves are not appropriations.
Inextricably Tied or Related to Appropriations
{¶ 31} The intervening respondents next claim that even if the challenged VLT provisions do not specifically set aside a sum of money for a specific public purpose, they are within the appropriations exception because they are “inextricably tied” to the $2.3 billion in appropriations from the Lottery Profits Education Fund for education provided by H.B. 1. Relators counter that the VLT sections are not within the Section Id, Article II exception, because they raise revenue rather than spend it.
Section 812.20
{¶ 32} The General Assembly specified in Section 812.20 of H.B. 1 that the amendment concerning VLTs in R.C. 3770.03 and 3770.21 is excluded from referendum because “it is or relates to an appropriation for current expenses within the meaning of Ohio Constitution, Article II, Section Id and section 1.471 of the Revised Code.” (Emphasis added.) This language, like the intervening respondents’ advocated construction of the exception, is broader than the applicable constitutional language, which states that “appropriations for the current expenses of the state government and state institutions * * * shall go into [331]*331immediate effect * * * [and] shall not be subject to referendum.” Section Id, Article II. The constitutional language does not expressly include an exception for laws that relate to appropriations for the current expenses of the state government.
{¶ 33} Moreover, this court has previously held that the analogous exception of Section Id, Article II for “laws providing for tax levies” is “limited to an actual self-executing levy of taxes, and is not synonymous with laws ‘relating’ to tax levies, or ‘pertaining’ to tax levies, or ‘concerning’ tax levies.” Keller, 108 Ohio St. 463, 141 N.E. 16, at paragraph three of the syllabus; see also State ex rel. Taft v. Franklin Cty. Court of Common Pleas (1998), 81 Ohio St.3d 480, 483, 692 N.E.2d 560 (holding that an act that authorizes the electorate to determine whether taxes should be levied does not levy taxes and consequently that Section Id, Article II does not apply).
{¶ 34} Therefore, notwithstanding the General Assembly’s language in Section 812.20 of the act, the VLT sections of H.B. 1 are not excepted from referendum if they merely relate to an appropriation for current state-government expenses; the exception is for appropriations for the current expenses of the state government — not for enactment of laws (other than tax levies) designed to generate revenue that can be appropriated.
{¶ 35} There is no authority in our precedent that would permit the referendum exception to apply to provisions that, once implemented, raise revenue to provide funds for an appropriation in another part of the act, even if — as the intervening respondents claim — they are “inextricably tied” or related to each other.
Kelly and Cty. Rd. Assn.
{¶ 36} Intervening respondents’ reliance on Kelly v. Marylanders for Sports Sanity, Inc. (1987), 310 Md. 437, 530 A.2d 245, and Cty. Rd. Assn. of Michigan v. Bd. of State Canvassers (1979), 407 Mich. 101, 282 N.W.2d 774, is unpersuasive and misplaced. Both cases involved legislation linked to an appropriation that the courts determined was not subject to referendum.
{¶ 37} In Kelly, the Court of Appeals of Maryland held that statutes authorizing the state stadium authority to borrow funds through the issuance of bonds and designating a site for the construction of professional baseball and football stadiums constituted appropriations that were not subject to referendum because those statutes were part of an interdependent and legally inseparable package of legislation that appropriated funds. 310 Md. at 474, 530 A.2d 245. Similarly, in Cty. Rd. Assn., the Supreme Court of Michigan concluded that statutes increasing various taxes on fuel and vehicle registrations constituted part of the appropriation to the highway department and were not subject to referendum.
[332]*332{¶ 38} Kelly and Cty. Rd. Assn. are distinguishable from the case before us because the state constitutions in those jurisdictions do not contain an exception from referendum for legislation that raises revenue by imposing a tax levy. See Section 2, Article 16, Maryland Constitution; Section 9, Article 2, Michigan Constitution.
{¶ 39} In contrast, the Ohio Constitution specifically exempts laws providing for tax levies from referendum. Section Id, Article II, Ohio Constitution. The electorate could have expressly excepted other means of raising revenue from referendum, but it did not. As we have consistently held, “ ‘[t]he canon expressio unius est exclusio alterius tells us that the express inclusion of one thing implies the exclusion of the other.’ ” Crawford-Cole v. Lucas Cty. Dept. of Job & Family Servs., 121 Ohio St.3d 560, 2009-Ohio-1355, 906 N.E.2d 409, ¶ 42, quoting Myers v. Toledo, 110 Ohio St.3d 218, 2006-Ohio-4353, 852 N.E.2d 1176, ¶24. In fact, if we were to read the appropriations exception to referendum as broadly as the intervening respondents advocate, the exception for tax levies would be meaningless because all means of raising revenue for government appropriations could be considered inextricably tied to appropriations.
{¶ 40} Our view is supported by the caselaw of other jurisdictions concluding that measures raising the revenue to be appropriated are not appropriations. See Nicholson v. Cooney (1994), 265 Mont. 406, 415-416, 877 P.2d 486 (rejecting the argument that a revenue-raising measure that was “inextricably tied” to appropriations legislation and that was used to balance the state budget fell within the appropriations exception to referendum); Lawrence v. Beermann (1974), 192 Neb. 507, 508-509, 222 N.W.2d 809 (explaining that the appropriations exception to referendum “should be and must be construed to mean the ordinary running expenses of the state government and existing state institutions, and not to include money or appropriations or funds created or acts which have as then-design a new or different scheme for * * * revenue raising and financing”); Brooks v. Zabka (1969), 168 Colo. 265, 270-271, 450 P.2d 653 (“The sales tax ordinance involved here is designed to raise revenue, not to provide for expenditures from public funds. * * * A sales tax ordinance is the exact antithesis of an appropriation” excepted from referendum); Heinkel v. Toberman (1950), 360 Mo. 58, 69, 226 S.W.2d 1012 (declining to construe a fuel tax as an appropriation, notwithstanding a separate constitutional provision requiring the funds generated by such taxes to be appropriated by the legislature for certain projects related to the state highway system).
Taft and Davies Mfg.
{¶ 41} The intervening respondents rely on State ex rel. Taft v. Franklin Cty. Court of Common Pleas (1998), 81 Ohio St.3d 480, 692 N.E.2d 560, and State ex rel. Davies Mfg. Co. v. Donahey (1916), 94 Ohio St. 382, 114 N.E. 1037, in support [333]*333of their argument that provisions of law that are inextricably tied to appropriations are exempt from referendum. This reliance, however, is misplaced.
{¶ 42} In Taft, we held that certain provisions of legislation imposing taxes to fund public schools were not subject to referendum although they did not appropriate money because implementation of those sections — calling for a statewide election on a proposed increase in the state sales and use tax— depended upon the appropriation of money for the election in a separate section of the same act. 81 Ohio St.3d at 484, 692 N.E.2d 560.
{¶ 43} Unlike the provisions at issue in Taft, the VLT provisions are not dependent upon any appropriation in H.B. 1. If anything, as the intervening respondents concede, the dependency is reversed: the appropriation of over $2.2 billion to the Department of Education from the Lottery Profits Education Fund is dependent, in part, upon the projected revenues from the enactment of the VLT provisions. The VLT provisions are also not dependent upon the provision in Section 305.10 of H.B. 1 authorizing the office of the inspector general to use $50,000 of its operating expenses in each fiscal year to defray any expenses associated with reviewing the VLT operations. Section 305.10 does not implement the VLT sections, and the inspector general need not use any money to review VLT operations.
{¶ 44} Intervening respondents’ reliance on Davies Mfg., 94 Ohio St. 382, 114 N.E. 1037, is also misplaced. There, we held that a competitive-bidding requirement was not subject to referendum, because it was only a condition for an appropriation for the current expenses of the state government; it never became part of the permanent law.
{¶ 45} In State ex rel. Ohio AFL-CIO v. Voinovich (1994), 69 Ohio St.3d 225, 631 N.E.2d 582, we explained that “ ‘[a]ny section of a law which changes the permanent law of the state is subject to referendum under the powers reserved to the people by Section 1 of Article II [of the Ohio Constitution], even though the law also contains a section providing for an appropriation for the current expenses of the state government and state institutions which under Section Id, Article II, becomes immediately effective.’ ” Id. at 236, 631 N.E.2d 582, quoting State ex rel. Riffe v. Brown (1977), 51 Ohio St.2d 149, 167, 5 O.O.3d 125, 365 N.E.2d 876 (O’Neill, C.J., dissenting). As Chief Justice O’Neill observed in distinguishing Davies Mfg. in Riffe, which was overruled in Ohio AFL-CIO, 69 Ohio St.3d at 236, 631 N.E.2d 582, “[t]o give practical effect to the constitutional exception for appropriations, temporary provisions needed to implement the appropriation must also be effective immediately. But a change in the permanent law governing the people of Ohio, which incidentally may require an appropriation, is a wholly different matter.” Riffe, 51 Ohio St.2d at 165, 365 N.E.2d 876.
[334]*334{¶ 46} The challenged VLT provisions are not temporary measures that are conditions upon the appropriations made from the lottery profits education fund. The VLT sections of H.B. 1 change the permanent law of this state by, inter alia, defining VLTs, requiring the State Lottery Commission to promulgate rules establishing the licensees’ minimum investments in buildings and grounds at the facilities where the VLTs will be located, barring new license or excise taxes on licensees after the effective date of the provisions, and purporting to vest exclusive, original jurisdiction in this court over any claims asserting that the VLT sections or any actions taken by the governor or State Lottery Commission pursuant to these sections are unconstitutional. Further, the amendment to R.C. 3770.03 permanently changes the law of Ohio by authorizing the Ohio Lottery Commission to operate VLT games, defined in proposed R.C. 3770.21(A) to mean “any electronic device approved by the state lottery commission that provides immediate prize determinations for participants on an electronic display.”
{¶ 47} The changes to the permanent law of the state distinguish the instant case from Taft and Davies Mfg., in which temporary measures were enacted to effectuate an appropriation. The VLT provisions at issue here constitute permanent changes that will be effective well after the biennium ends and are thus subject to referendum.
{¶ 48} A different section of the Ohio Constitution also supports our conclusion that the VLT provisions of H.B. 1 are not an appropriation. Section 22, Article II of the Ohio Constitution provides that “no appropriation shall be made for a longer period than two years.” In contrast to this temporal limitation, the VLT provisions of H.B. 1 — R.C. 3770.03 and 3770.21 — do not expire in two years and are designed to become a permanent part of state law for purposes of generating state income. As such, these provisions are not appropriations.
{¶ 49} The plain language of Section Id, Article II of the Ohio Constitution provides three limited exceptions to referendum: laws providing for tax levies, appropriations for the current expenses of the state government, and emergency laws necessary for the immediate preservation of the public peace, health, or safety, none of which expressly excepts changes to the permanent law of this state that provide a mechanism to raise revenue to provide funds for an appropriation. Courts are not authorized to add exceptions that are not contained in the express language of these constitutional provisions. Cf., e.g., State ex rel. Stoll v. Logan Cty. Bd. of Elections, 117 Ohio St.3d 76, 2008-Ohio-333, 881 N.E.2d 1214, ¶ 39 (“the statute contains no exception, and we cannot add one to its express language”).
{¶ 50} The intervening respondents’ interpretation of the appropriations exception would mean that even if the electorate repealed the tax-levy exception, laws providing for tax levies would remain excluded from referendum because they are [335]*335“inextricably tied” or “related” to appropriations. In addition, under this interpretation of Section Id, Article II of the Ohio Constitution, the General Assembly could presumably enact laws to raise revenue for appropriations by legalizing drugs or prostitution and thereby prevent the electorate from seeking referendum on the manner it chose to generate revenue to be used for an appropriation. This is not the meaning of Section Id, Article II of the Ohio Constitution. See State ex rel. Colvin v. Brunner, 120 Ohio St.3d 110, 2008-Ohio-5041, 896 N.E.2d 979, ¶ 58 (courts have duty to construe constitutional provisions to avoid unreasonable or absurd results). Our duty is to construe the meaning of the plain language of the Constitution.
{¶ 51} Finally, we decline the invitation of the intervening respondents to address whether the State Lottery Commission is authorized to implement VLTs regardless of whether the challenged provisions of H.B. 1 are effective, because the parties have not submitted complete evidence and argument on this issue. We confine our opinion here to only the narrower issue raised in this case regarding the rights of citizens to a referendum on the VLT provisions of H.B. 1. Furthermore, declining to address a legal issue not squarely before us is consistent with our reluctance to issue advisory opinions, the principle of judicial restraint, and our duty to liberally construe election laws in favor of the right to vote. State ex rel. Myles v. Brunner, 120 Ohio St.3d 328, 2008-Ohio-5097, 899 N.E.2d 120, ¶ 26, fn. 2, quoting State ex rel. Barletta v. Fersch, 99 Ohio St.3d 295, 2003-Ohio-3629, 791 N.E.2d 452, ¶ 22 (“ ‘we will not issue advisory opinions, and this rule applies equally to election cases’ ”); PDK Laboratories, Inc. v. United States Drug Enforcement Admin. (C.A.D.C.2004), 362 F.3d 786, 799 (Roberts, J., concurring in part and in judgment) (recognizing the “cardinal principle of judicial restraint — if it is not necessary to decide more, it is necessary not to decide more”); Colvin, 120 Ohio St.3d 110, 2008-Ohio-5041, 896 N.E.2d 979, ¶ 62 (noting the court’s “duty to liberally construe election laws in favor of the right to vote”).
Conclusion
{¶ 52} Accordingly, relators, LetOhioVote.org, Brinkman, Hansen, and Pierce, have established entitlement to the requested extraordinary relief in mandamus, and the secretary of state is directed to accept the submission of relators’ referendum-petition summary and to discharge the duties of her office as provided by Article II of the Ohio Constitution and R.C. 3519.01.
{¶ 53} The video-lottery-terminal provisions of 2009 Am.Sub.H.B. No. 1 do not fall within any of the exceptions to the right of referendum in that they are neither laws providing for tax levies, nor appropriations for the current expenses of the state government, nor emergency laws necessary for the immediate [336]*336preservation of the public peace, health, or safety. Therefore, they are subject to referendum.
{¶ 54} In conformity with our decision in Ohio AFL-CIO, 69 Ohio St.3d at 236-237, 631 N.E.2d 582, and as acknowledged by the respondents at oral argument, relators are entitled to an extension of the 90-day period in which to submit a referendum petition on the VLT provisions to the secretary of state. We therefore stay the amendments to R.C. 3770.03 and the enactment of R.C. 3770.21, which are the VLT provisions of H.B. 1, for 90 days from the date of this decision in order to allow relators a meaningful opportunity to circulate a referendum petition.
{¶ 55} Ours is still a representative democracy in which legislators derive their authority from the citizens of our state, who enjoy a constitutional right of referendum. While the Ohio Constitution expressly provides that appropriations for the current expenses of the state government are not subject to referendum, permanent changes to state law relating to such appropriations are subject to referendum. We are not unmindful of the effect our decision may have on the state budget, nor of the commendable efforts of the members of the executive and legislative branches of state government to fulfill their constitutional duties to balance the budget in Ohio; however, our own constitutional duty is to ensure compliance with the requirements of the Ohio Constitution irrespective of their effect on the state’s current financial conditions.
Writ granted.
Moyer, C.J., and Lundberg Stratton, O’Connor, Lanzinger, and Cupp, JJ., concur.
Pfeifer, J., dissents.