Arizona Supreme Court

Arizona Citizens Clean Elections Commission; Louis J. Hoffman; Victoria Steele; Arizona Advocacy Network…

April 2, 2014234 Ariz. 322

Summary

The court held that the Citizens Clean Elections Act establishes a formula under which contribution limits for nonparticipating candidates equal twenty percent less than the limits specified in the referenced statute, as periodically adjusted, rather than fixing limits at eighty percent of the 1998 amounts. Applying de novo statutory interpretation, the court found the text ambiguous but concluded that the formula interpretation best served the voters’ intent and avoided anomalous and confusing results. The court vacated the court of appeals’ opinion and affirmed the superior court’s denial of a preliminary injunction.