Sjostrom v. Bishop

In Sjostrom v. Bishop, 15 Utah 2d 373, 393 P.2d 472 (Utah 1964), candidates did not timely file their post-election disclosure statements, yet we held that the candidates had substantially complied with the deadlines and would not be removed from office. (Id. at 475.) Sjostrom, specifically distinguished conduct that was to take place before an election from conduct that was to take place after an election. It stated: "Where statutes governing the conduct of elections require something to be done before the election, so it might have some influence on the election's outcome, it is usually held that the time requirement is mandatory. But where it is not to be done until after the election, so that compliance would not affect the result, the provision as to time is generally considered to be directory only." (Id. at 474.)