Cited by

at 297 ¶ 27 (stating that the purpose of the description is to enable prospective signatories to determine whether to endorse the measure for the ballot); (observing that “rare is the elector who stops long enough in the summer heat to read or listen to a complete description of the entire nature and scope of a proposed measure”).

(denying the prevailing, defending party’s request for attorney fees, explaining he had failed to “cite express authority” for such an award and the court “desire[d] to avoid placing a chill on future petition challenges by private citizens”).

-56 (1991) (stating that § 19-122(C) “permits any citizen to explore beyond the county recorder’s certification” of signatures).

Nevertheless, in Kromko v. Superior Court, this Court criticized using extraneous “short titles” in petition sheets that “contain[] either untrue representations designed to defraud potential signatories, or highly inflammatory language calculated to incite partisan rage.”

22, ¶ 6 (2015) ( ¶ 11 (2006)); ¶ 7 (2012) (“[C]ourts liberally construe initiative requirements and do not interfere with the people’s right to initiate laws ‘unless the Constitution expressly and explicitly makes any departure from initiative filing requirements fatal.’”) ().

Thus, “courts liberally construe initiative requirements and do not interfere with the people’s right to initiate laws ‘unless the Constitution expressly and explicitly makes any departure [from initiative filing requirements] fatal.’” Id., (alteration in Pedersen).

ts - 5 - liberally construe initiative requirements and do not interfere with the people’s right to initiate laws “unless the Constitution expressly and explicitly makes any departure [from initiative filing requirements] fatal.” Kromko v. Superior Court, 168 Ariz. 51, 58, (internal quotation marks and citations omitted); see also 1989 Ariz. Sess.

at 48, ¶ 15 , 192 P.3d at 407 ( , ).

Subsection (C) contains no time limitation, but we have held that any suit under this provision “must be initiated and heard in time to prepare the ballots for absentee voting to avoid rendering an action moot.”

¶13 In rejecting Wilhelm’s arguments, the superior court relied on our decision in Kromko v. Superior Court (Miller), P.2d 12 (1991).

¶ 15, Mathieu v. Mahoney, 174 Ariz. 456, 458-59, -84 (1993)

¶13 In contrast, “requirements as to the form and manner in which citizens exercise their power of initiative should be liberally construed.” -58, -19 (1991).

See, (noting that the “concern with timeliness stems in part from the notion that ‘disputes concerning election and petition matters must be initiated and heard in time to prepare the ballots for absentee voting to avoid rendering an action moot’”) ( ).

The doctrine of laches has recently been applied in one election case, , and rejected in another

(a measure’s text is part of legislative process and not subject to review before adoption); , (court’s power to halt placing initiative on auto insurance reform on ballot is limited); , (court will enjoin neither city council nor electorate from adopting ordinance if it is legislative and within scope of municipal powe