Citizens Clean Elections Commission v. Myers
In Citizens Clean Elections Commission v. Myers, 196 Ariz. 516, 520,14, 1 P.3d 706, 710 (2000), the Arizona Supreme Court stated: "The legislature need not look to an express grant of authority in order to justify an enactment.
But . . . any exercise of legislative power is subject to the limitations imposed by the constitution.
And just as no express grant of authority is required, there is no requirement that a limitation be express." Myers therefore determined that "a limitation may be implied by the text of the constitution or its structure taken as a whole." Id. at 521,14, 1 P.3d at 711.