State v. Marshall

In State v. Marshall, 633 P.2d 227, 229 (Alaska 1981), a case involving a statute requiring candidates to file a list of election contributions seven days before an election and imposing sanctions where such deadlines are not met, the Alaska Supreme Court held that candidates must strictly comply with the statute. The Alaska court also distinguished statutes requiring specific conduct prior to an election from those requiring conduct subsequent to the election. Id. at 234-35. The court stated, "pre-election reports, as opposed to post-election reports, do provide the electorate with information that may affect its decision; manifestly the timeliness of those reports is critical." Id. at 235. Because they provide the electorate with such important information, "election law filing deadlines are mandatory, and therefore substantial compliance is not sufficient." Id.