Martindale v. Anderson
In Martindale v. Anderson, 581 P.2d 1022 (Utah 1978), the Court confronted the task of identifying the composition of the "governing body" of a municipality that had selected a strong mayor form of government.
There, we expressed the view that "the inconsistencies in the terminology of the statutes in referring to the approving authority for the sale of municipal property and approval of subdivisions is of some concern." Id. at 1028.
The Court observed that those inconsistencies had led the district court to "place undue emphasis" on statutory language that defined the city council as the "governing body." Id. at 1027.
Concluding that the district court's interpretation was too narrow, we looked beyond the language of the statute to the legislative history of municipal government in Utah and determined that under the facts of Martindale, "governing body" should be defined generically, free of any linkage to the functions of any particular governing body. Id. at 1028.