Mayor of Tucson v. Royal

In Mayor of Tucson v. Royal, 20 Ariz. App. 83, 510 P.2d 394 (1973), government officials created a redistricting plan pursuant to the city charter in order to equalize population in six voting wards. Id. at 83-84, 510 P.2d at 394-95. Three of the wards held primary and at-large elections in 1973, while the remaining three wards held elections in 1975. Id. at 84, 510 P.2d at 395. The redistricting plan dispersed voters among all wards, thereby depriving approximately 47,000 voters of the ability to vote in the 1973 primary election. Id. The Royal court concluded that "laws which impair the right to vote are unconstitutional unless the governmental body can demonstrate that the laws are necessary to promote a compelling governmental interest." Id. at 87, 510 P.2d at 398. It upheld the trial court's decision to strike the redistricting plan because it was not necessary to promote a compelling governmental interest "in the face of the temporary disenfranchisement of thousands of voters" when there existed "an apparent less disruptive alternative." Id. at 89, 510 P.2d at 400.