In Alaskans for Legislative Reform v. State, 887 P.2d 960 (Alaska 1994), the Alaska Supreme Court found a legislative term limit initiative unconstitutional for several reasons, including: (1) when the conflicting principles of constitutional government and the people's right to express their will conflict, the former must prevail; (2) the constitutional qualifications are exclusive even though not explicitly so; (3) and office-holding qualifications are not mere election regulations.