Arizona Revised Statutes

Ariz. Rev. Stat. § 9-284 (2026)

Effect of charter on inconsistent laws

✓ current as of May 2026
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A. When the charter has been framed, adopted and approved, and any of its provisions are in conflict with any law relating to cities containing a population of more than three thousand five hundred inhabitants in force at the time of the adoption and approval of the charter, the provisions of the charter shall prevail notwithstanding the conflict, and shall operate as a repeal or suspension of the law to the extent of conflict, and the law shall not thereafter be operative as to such conflict.

B. The charter shall be consistent with and subject to the state constitution, and not in conflict with the constitution and laws relating to the exercise of the initiative and referendum and other general laws of the state not relating to cities.

C. Notwithstanding any statute, the charter may authorize agreements setting wages and salaries which extend not more than two years beyond the term of the contracting council.

Notes of Decisions
Cited in 15 cases (1 in the last 5 years), 1976–2021 · leading case: State Ex Rel Brnovich v. City of tucson/dewit, 399 P.3d 663 (Ariz. 2017).
State Ex Rel Brnovich v. City of tucson/dewit, 399 P.3d 663 (Ariz. 2017). · cites it 24× “Shortly after the Constitution’s ratification, the legislature passed an emergency statute presently codified as A.R.S. § 9-284 (the “charter statute”). Section 9-284(A) provides that where charter provisions “are in conflict with any law” relating to cities eligible for charter…”
City of Phoenix v. Harnish, 150 P.3d 245 (Ariz. Ct. App. 2006). · cites it 7× “Section 9-284(B), however, mandates that the charter “shall be consistent with and subject to the state constitution, and not in conflict with .”
City of Casa Grande v. Arizona Water Co., 20 P.3d 590 (Ariz. Ct. App. 2001). · cites it 4× “Relying on A.R.S. § 9-284(A), the City argues that, because its charter “expressly empowers the City to engage in the water utility business,” and because it had enacted an ordinance to do so by exercising its power of eminent domain, the charter’s authority “prevails over…”
State v. McLamb, 932 P.2d 266 (Ariz. Ct. App. 1996). · cites it 2× “1978); see A.R.S. § 9-284. The defendant argues that Code section 23-21 is preempted by A.”
Prendergast v. City of Tempe, 691 P.2d 726 (Ariz. Ct. App. 1984). · cites it 2× “1978); A.R.S. § 9-284(B) (Supp.1983). Where a subject is of statewide concern and the legislature has appropriated the field by enacting a statute pertaining thereto, any conflicting ordinances are invalid.”
Shaffer v. Allt, 545 P.2d 76 (Ariz. Ct. App. 1976). · cites it 2× “Turning to the first issue presented, that is, the authority (power) of the city of Yuma to hold a liquor license and engage in the business of selling alcoholic beverages, we must start with the scope of the City’s power as a charter city.”
City of Phoenix v. Long, 761 P.2d 133 (Ariz. Ct. App. 1988). · cites it 2× “See A.R.S. § 9-284. Thus, as to Phoenix, § 9-402 would be in any event inapplicable.”
State v. Jacobson, 588 P.2d 358 (Ariz. Ct. App. 1978). · cites it 2× “See A.R.S. § 9-284; Shaffer v. Allt, 25 Ariz.”
City of Tucson v. Consumers for Retail Choice, 5 P.2d 934 (Ariz. Ct. App. 2000). · cites it 2× “See also *603 A.R.S. § 9-284(B). But there must be an actual conflict.”
Union Transportes De Nogales v. City of Nogales, 985 P.2d 1025 (Ariz. 1999). · cites it 2× “; see also A.R.S. § 9-284(B) (Charter must be “consistent with and subject to .”
Puppies 'N Love v. City of Phoenix, 116 F. Supp. 3d 971 (D. Ariz. 2015). · cites it 2× “2d 426, 429 (1994); see also A.R.S. § 9-284(B). The City of Phoenix “is granted áutonomy over matters of local interest.”
Ryder Truck Rental v. City of Phoenix, 838 P.2d 829 (Ariz. T.C. 1992). · cites it 2× “05(I) preempts the City of Phoenix from imposing its privilege tax on Ryder's leasing activities. A charter *500 city such as Phoenix may exercise all the powers authorized by its charter, insofar as those powers are consistent with the Arizona Constitution and do not conflict…”
— Ariz. Rev. Stat. § 9-284(A) — 5 cases
State Ex Rel Brnovich v. City of tucson/dewit, 399 P.3d 663 (Ariz. 2017). “Shortly after the Constitution’s ratification, the legislature passed an emergency statute presently codified as A.R.S. § 9-284 (the “charter statute”). Section 9-284(A) provides that where charter provisions “are in conflict with any law” relating to cities eligible for charter…”
City of Casa Grande v. Arizona Water Co., 20 P.3d 590 (Ariz. Ct. App. 2001). “Relying on A.R.S. § 9-284(A), the City argues that, because its charter “expressly empowers the City to engage in the water utility business,” and because it had enacted an ordinance to do so by exercising its power of eminent domain, the charter’s authority “prevails over…”
City of Phoenix v. Harnish, 150 P.3d 245 (Ariz. Ct. App. 2006). “Section 9-284(B), however, mandates that the charter “shall be consistent with and subject to the state constitution, and not in conflict with .”
— Ariz. Rev. Stat. § 9-284(B) — 12 cases
State Ex Rel Brnovich v. City of tucson/dewit, 399 P.3d 663 (Ariz. 2017). “Shortly after the Constitution’s ratification, the legislature passed an emergency statute presently codified as A.R.S. § 9-284 (the “charter statute”). Section 9-284(A) provides that where charter provisions “are in conflict with any law” relating to cities eligible for charter…”
City of Phoenix v. Harnish, 150 P.3d 245 (Ariz. Ct. App. 2006). “Section 9-284(B), however, mandates that the charter “shall be consistent with and subject to the state constitution, and not in conflict with .”
Prendergast v. City of Tempe, 691 P.2d 726 (Ariz. Ct. App. 1984). “1978); A.R.S. § 9-284(B) (Supp.1983). Where a subject is of statewide concern and the legislature has appropriated the field by enacting a statute pertaining thereto, any conflicting ordinances are invalid.”
City of Casa Grande v. Arizona Water Co., 20 P.3d 590 (Ariz. Ct. App. 2001). “Relying on A.R.S. § 9-284(A), the City argues that, because its charter “expressly empowers the City to engage in the water utility business,” and because it had enacted an ordinance to do so by exercising its power of eminent domain, the charter’s authority “prevails over…”
Shaffer v. Allt, 545 P.2d 76 (Ariz. Ct. App. 1976). “Turning to the first issue presented, that is, the authority (power) of the city of Yuma to hold a liquor license and engage in the business of selling alcoholic beverages, we must start with the scope of the City’s power as a charter city.”
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