Harris v. City of Bisbee

In Harris v. City of Bisbee, 219 Ariz. 36, n.3, 192 P.3d 162, 166 n.3 (App. 2008), the Court acknowledged that referenda are subject to a strict compliance standard. 219 Ariz. 36,13, 192 P.3d at 166. But, the Court noted, consistent with the strong public policy in this state that favors facilitating the referendum process, "our courts have held that, unless the failure to comply strictly with a statutory requirement is expressly made fatal, that failure 'does not make the signatures appearing on the petitions null and void, but merely destroys their presumption of validity.'" Id.14, 21. The Court found that although the presumption of validity had been destroyed by the lack of strict compliance in two primary respects, it had been restored as to some of the signatures. Id.21-22.