Ariz. Rev. Stat. » Title 19
Arizona Revised Statutes

Ariz. Rev. Stat. § 19-101.01 (2026)

Legislative findings and intent; strict compliance

✓ text as last checked Oct. 2026 (this copy records no edition or section history)
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19-101.01. Legislative findings and intent; strict compliance

The legislature recognizes that a referendum may overrule the results of determinations made by representatives of the people and therefore finds and determines that strict compliance with the constitutional and statutory requirements for the referendum process and in the application and enforcement of those requirements provides the surest method for safeguarding the integrity and accuracy of the referendum process. Therefore, the legislature finds and declares its intent that the constitutional and statutory requirements for the referendum be strictly construed and that persons using the referendum process strictly comply with those constitutional and statutory requirements.

 

Notes of Decisions
Cited in 12 cases (10 in the last 5 years), 2017–2026 · leading case: Voice of Surprise v. Skip Hall, 533 P.3d 942 (Ariz. 2023).
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Voice of Surprise v. Skip Hall, 533 P.3d 942 (Ariz. 2023). · cites it 13× “¶9 We granted review of VOS’s petition for review to decide whether the City Clerk properly rejected the petition sheets and all signatures based solely on the application error.”
Mussi v. Katie hobbs/adrc Action, 532 P.3d 1131 (Ariz. 2023). · cites it 2× “This is, by no means, an obvious result, as demonstrated by the several different calculation methods used by the trial court, the parties, the majority, and me, all of which are purportedly based on the same statutes.”
Shane Noel Jones & Victoria Cranford v. Respect the Will of the People, 517 P.3d 1188 (Ariz. Ct. App. 2022). · cites it 10× “But, we also noted that our legislature had expressly 7RWP suggests that Jones did not raise this argument below but does not argue that we should consider the issue waived. Although Jones did not apparently argue that Sklar was no longer good law before the trial court, he did…”
Voice v. Hall, No. 1 CA-CV 22-0696 (Ariz. Ct. App. Apr. 27, 2023). · cites it 14× “, one of the Private Defendants, urged the City Clerk to reject the petition sheets for that same reason, also arguing the petition sheets failed to include an adequate description of the measure to be referred and that the ordinance was not a “legislative act” subject to…”
Voice v. Hall, No. 1 CA-CV 22-0696 (Ariz. Ct. App. Feb. 7, 2023). · cites it 10× “, one of the Private Defendants, urged the City Clerk to reject the petition sheets for that same reason, also arguing VOS failed to include an adequate description of the measure to be referred on the petition sheets and that the Ordinance was not a “legislative act” subject to…”
Az Free Enter. Club v. Katie Hobbs, 515 P.3d 664 (Ariz. 2022). · cites it 2× “Section 1(3) provides: The second of these reserved powers is the referendum.”
Workers v. Tempe, No. 1 CA-CV 22-0395 (Ariz. Ct. App. Jan. 24, 2023). · cites it 4× “Riffel, 213 Ariz. 247, 249, ¶ 6 (App. 2006) (noting strict compliance "requires nearly perfect compliance").”
Workers v. Tempe, No. 1 CA-CV 22-0395 (Ariz. Ct. App. Jan. 26, 2023). · cites it 4× “Riffel, 213 Ariz. 247, 249, ¶ 6 (App. 2006) (noting strict compliance "requires nearly perfect compliance").”
Voice of Surprise v. Skip Hall, No. CV-23-0117-PR (Ariz. June 23, 2023). · cites it 4× “01, Appellants’ failure to file an application that strictly complied with § 19-111(A) was fatal to the referendum effort.”
Taxpayers v. Price, 418 P.3d 1103 (Ariz. Ct. App. 2017). · cites it 2× “2d 767 , 770 (1991) (enacted legislation may reflect view of majority); A.R.S. § 19-101.01 (requiring "strict compliance with the constitutional and statutory requirements for the referendum process").”
Arizonans for Fair Elections v. Hobbs, No. 2:20-cv-00658, 2020 WL 1905747 (D. Ariz. Apr. 17, 2020). · cites it 2× “R.S. § 19-101.01 (emphasis added). It has made 4 the same finding with respect to the initiative process.”
Evans v. Fernandez, No. 1 CA-CV 25-1068 (Ariz. Ct. App. June 17, 2026). · cites it 2× “Using a harmless error standard “would mean advancing a referendum effort that only substantially complied with 6 statutory requirements in violation of the legislative directive for strict compliance.”
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