The North Carolina Constitution stipulates that the governor and General Assembly must balance the budget each year. Article III, Section 5 reads: “The total expenditures of the State for the fiscal period covered by the budget shall not exceed the total of receipts during that fiscal period and the surplus remaining in the State Treasury at the beginning of the period.” In order to accomplish this end, the executive branch (i.e., the governor) is charged with the following duties: “To insure that the State does not incur a deficit for any fiscal period, the Governor shall continually survey the collection of the revenue and shall affect the necessary economies in State expenditures.” The Balanced Budget Amendment was submitted by the General Assembly and ratified by voters in 1977 with the intention of reigning in state spending, as indicated by the fact that the amendment explicitly requires that “economies in State expenditures” be made to balance the budget. At times, however, the amendment has been used as an excuse to raise, or refrain from cutting, taxes. In recent years, in particular, the governor has sought to balance the budget, not by taking “necessary economies,” but by illegally taking revenue from reserve funds not intended for general spending.