Strode v. Sfullivan

In Strode v. Sfullivan, 72 Ariz. 360, 364-65, 236 P.2d 48, 51 (1951), the Arizona Supreme Court did not apply any particular test but stated that it could "conceive of no essentials more inherently of local interest or concern to the electors of a city than who shall be its governing officers and how they shall be selected." 72 Ariz. at 368, 236 P.2d at 54. The court went on to hold "that the method and manner of conducting municipal elections . . . are peculiarly the subject of local interest and are not . . . matters of statewide concern." Id. In Strode, the Arizona Supreme Court was considering whether a state law requiring disclosure of partisan affiliations in city council elections would supersede the charter of the City of Phoenix, which required nonpartisan city council elections. 72 Ariz. at 361-62, 236 P.2d at 49-50. The court held "that the method and manner of conducting municipal elections . . . are peculiarly the subject of local interest and are not . . . matters of statewide concern." Id. at 368, 236 P.2d at 54.