By: McKenna Hunter.
In 2023, the Arizona Supreme Court ruled on a challenge to a local ordinance via referendum. While the appeal focused on a statutory aspect of Arizona referendum law, the Court showed open-mindedness to a potential challenge to the strict compliance requirement for referendums with state law. Although only recognizing as-applied challenges to the requirement, this Note looks at the deeper facial challenge that exists to the strict compliance requirement. Looking at the effect of the Voice of Surprise v. Hall ruling and the history behind direct democracy provisions in the Arizona Constitution, this Note argues for the removal of the requirement for referenda.