Cited by

hington Supreme Court has observed when interpreting the speech clause that Arizona adopted as our Speak Freely Clause, see Stummer, 219 Ariz. at 142 ¶ 14 n.4, a state constitutional provision may sometimes be more protective than its federal counterpart, but “it does not follow that greater protection is provided in all contexts.” See Ino Ino, 937 P.2d at 162, 166; –06 (1999) (Feldman, J., dissenting) (finding that “Washington cases interpreting their constitution are persuasive authority with

Co. v. Wilmington Trust, N.A., ¶ 11 (2023) (“Our statutory interpretation jurisprudence requires us to determine the plain meaning of the words the legislature chose to use, viewed in their broader statutory context.”); ¶ 68 (1999) (“We alone must decide how persuasive the legal opinions of other jurisdictions will be to our holdings.”).

(noting Arizona courts have discretion in accepting another jurisdiction’s interpretation of its laws).

¶ 68 (1999) (“We alone must decide how persuasive the legal opinions of other jurisdictions will be to our holdings.”).

¶29 Contrary to the City’s argument

When the Arizona Constitution does not define its terms, we “look to their ‘natural, obvious, and ordinary meaning,’” ¶ 33 (1999) (quoting Cnty.

See, ¶ 68 (1999) (concluding that we may find useful guidance in Washington State jurisprudence as much of our constitution was derived from theirs).

314-15 ¶ 27, -78 (2005) (providing that when we can avoid constitutional doubt by interpreting a statute in a manner that does no violence to its text, we will adopt that interpretation); , 284 ¶ 31, (“[W]e resolve all uncertainties [regarding a statute] in favor of constitutionality.”).

273, 287, ¶ 46, -52 , -64 (1967).

¶ 20 , ( , Gaethje v. Gaethje, 7 Ariz.App.

-41, ¶ 32 , -94 (App.2010) (citation omitted) (declining to impose duties set forth in cases from other jurisdictions, noting that “we are not bound by the decisions of other states”); -92, ¶ 68 , -25 (1999) (noting that “while Washington’s judicial decisions may prove useful, they certainly do not control Arizona law.

Nonetheless, municipalities may have understood the “public benefit” language 26 to suggest a broader view of “consideration.” Cf. Kotterman v. Killian, 193 Ariz. 273, 288 ¶ 51, (citing Wistuber for the proposition that “[w]e have upheld giving when the state action served a public purpose and adequate consideration was

(stating that a court “must decide how persuasive the legal opinions of other jurisdictions will be to [its] holdings”); -47 , -82 (1968) (recognizing that the trial court relied on Washington case law over California and Texas c

¶ 52 , (holding income tax credit is not a gift); , 289 P. 515, 519 (1930) (finding garnishment of state employee would not involve public funds).

273, 278, ¶ 8, (“[Private schools] also further the objective of making quality education available to all children within a state.”).

¶ 46, -52, -64 (1967), suggest that Arizona’s Religion Clause is “virtually indistinguishable from the United States Supreme Court’s interpretation of the federal Establ

419 , 89 S.E.2d 851, 855, 858 (1955) (considering similar clauses in Virginia Constitution); , (Feldman, J., dissenting) (noting article IX, § 10 based on “Arizona’s strong policy of refusing to fund private or sectarian education”).

disregard them.”); , (“[S]tate courts are not bound by decisions of federal circuit courts.”); , (decisions of other state courts are “useful” but “do not control Arizona law”).

1673 , 72 L.Ed.2d 33 (1982); ¶ 2

“We interpret constitutional provisions by examining the text and, where necessary, history in an attempt to determine the framers’ intent.” ¶ 54, (quoting Boswell v. Phoenix Newspapers, Inc., (emphasis added)).