Clark v. City of Aurora

Justice LOHR

concurring in part and dissenting in part:

I concur with the court that the power of referendum reserved to the people by Article V, Section 1, of the Colorado Constitution is not facially infringed by those portions of the Aurora City Code that require referendum petition signers to print their names, Aurora City Code § 14-12(B) (1979), to provide their house and/or apartment numbers, id., to provide their complete addresses, §§ 14-12(B), -13(A)(4), and to indicate their cities and counties of residence, §§ 14-12(B), -13(A)(5). However, I respectfully dissent from the court’s holding that section 14-13(A)(7), which prohibits the use of ditto marks, does not facially encroach upon the power of referendum reserved to the people by our state constitution.

I.

As the majority acknowledges, the right to referendum is fundamental. Maj. op. at 777. Article V, Section 1, of the Colorado Constitution, which reserves the power of referendum to the people, and the statutes that implement it “must be liberally construed so as not to unduly limit or curtail the exercise of the initiative and referendum rights.” Billings v. Buchanan, 192 Colo. 32, 35, 555 P.2d 176, 178 (1976). Although municipalities may enact procedures designed to eliminate mistake, fraud and other abuses in the referendum process, maj. op. at 778, they may not establish requirements that, singly or in combination, unnecessarily restrict the right to referendum. See Urevich v. Woodard, 667 P.2d 760, 762 (Colo.1983) (invalidating legislative limitations on right of initiative); Colorado Project-Common Cause v. Anderson, 178 Colo. 1, 5, 495 P.2d 220, 222 (1972) (same); Yenter v. Baker, 126 Colo. 232, 237, 248 P.2d 311, 314 (1952) (same). The referendum right may not be “hampered by either technical statutory provisions or technical construction thereof, further than is necessary to fairly guard against fraud and mistake.” Brownlow v. Wunsch, 103 Colo. 120, 123, 83 P.2d 775, *783777 (1938) (quoting State ex rel. Case v. Superior Court, 81 Wash. 623, 632, 143 P. 461, 464 (1914)).

II.

I agree with the majority that the requirement that signers’ addresses include designations such as north, south, east or west, as well as street, avenue, drive or way may often be necessary, but that “wooden application [of this requirement] might unduly impair an individual’s right of referendum.” Maj. op. at 781. I would also hold that wooden application of the requirement in section 14-12(B) of the Aurora City Code that the signer’s name be printed after his or her signature might likewise impair the right to referendum. Although signatures may often be illegible, the requirement that a printed name follow the signature hampers, rather than facilitates, the referendum process when a signature is legible. Likewise, the requirements that a signature be accompanied by the signer’s house and/or apartment number, § 14-12(B), and the signer’s city and county of residence, §§ 14-12(B), -13(A)(5), might impair the right to referendum if applied woodenly. Although an indication of the county of residence may be necessary in some instances, in others the county may be readily apparent from the other information provided. Similarly, it is conceivable that in some situations an elector’s residence qualification could be easily determined without the elector’s house or apartment number. Because the majority opinion addresses only the facial constitutionality of Aurora’s City Code provisions, I do not read it to preclude later challenges of these requirements as they are applied in specific situations.

III.

Finally, I would hold unconstitutional section 14-13(A)(7), which requires the city clerk to find signatures insufficient if the signer used ditto marks as a substitute for any required information. The majority states that “the primary justification for requiring a petition signer to provide information with respect to identity and residence is to safeguard the integrity of the referendum process by allowing the city clerk to initially determine whether a particular petition signer is a qualified registered elector and to permit anyone interested in protesting the petition likewise to confirm or disprove the voting eligibility of a petition signer.” Maj. op. at 782. The prohibition of the use of ditto marks is not justified on this ground. Ditto marks are used to incorporate information supplied by the previous petition signer. The majority contends that the incorporated information may be partially or totally incorrect. Id. However, the use of ditto marks does not increase the always-present risk that a signer will include inaccurate information on a petition. The majority asserts that requiring a signer to write out the information assures that the information comes from the signer, the best source available, but that the use of ditto marks results in a reliance on a secondary source for the information. This analysis fails to take into account the fact that by putting ditto marks on a petition, the signer asserts that the information incorporated from the previous line is correct as applied to the signer. The ditto marks represent a kind of short-hand that is, nonetheless, first-person, primary-source information. Because prohibiting the use of ditto marks serves no purpose sufficiently important to justify the resulting frustration of the right to referendum, I would hold section 14-13(A)(7) unconstitutional on its face.

KIRSHBAUM, J., joins in this concurrence and dissent.