In Valencia Energy Co. v. Arizona Department of Revenue, 191 Ariz. 565, 959 P.2d 1256 (1998) the Arizona Supreme Court outlined the circumstances in which estoppel may be applied against the government. The court stated: "The three elements of equitable estoppel are traditionally stated as: (1) the party to be estopped commits acts inconsistent with a position it later adopts; (2) reliance by the other party; (3) injury to the latter resulting from the former's repudiation of its prior conduct." Id. P35. The court in Valencia further stated "all these requirements are conditioned by the general rule that estoppel may apply against the state only when the public interest will not be unduly damaged and when its application will not substantially and adversely affect the exercise of governmental powers." 191 Ariz. 565, P40, 959 P.2d at 1269.