Roundtree v. Page, 573 P.3d 65

The City of Page proposed a "Streetscape Project" to reduce the number and width of lanes on a portion of Lake Powell Boulevard to revitalize downtown after economic decline.
Plaintiffs (including the Page Action Committee and city residents) drafted an initiative to preserve the street’s existing lane configuration, prohibiting any narrowing or reduction.
The City of Page refused to place the initiative on the ballot, arguing it was not a legislative act and thus not permissible under the Arizona Constitution’s local initiative provisions.
The superior court and court of appeals both sided with the City, holding the initiative was administrative (not legislative) in nature.
The Arizona Supreme Court granted review to determine whether the initiative properly falls within the citizens’ local legislative power under Article 4, Part 1, Section 1(8) of the Arizona Constitution.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Scope of citizen initiative power under Ariz. Const.	Citizens can initiate measures on any matter, not just legislative acts	Power is limited to legislative matters as authorized by general laws	Initiative power is limited to legislative matters
Whether the initiative is legislative or administrative	Initiative sets new, permanent policy (legislative in nature)	Only implements/blocks existing policy, thus is administrative	Initiative is legislative and may proceed to ballot
Application of Wennerstrom test to initiatives	Test should not bar policy-creating initiatives	Test shows initiative is administrative since city had already set the policy	Test is helpful but not dispositive; initiative qualifies
Whether existing city delegation to engineer precludes initiative	Previous delegation does not bar legislative action by voters	Initiative wrongly interferes with delegated administrative authority	Existing delegation does not preclude voter legislation

Wennerstrom v. City of Mesa, 169 Ariz. 485 (Ariz. 1991) (establishes legislative vs. administrative distinction for local ballot measures)
League of Ariz. Cities & Towns v. Brewer, 213 Ariz. 557 (Ariz. 2006) (initiative power is co-equal with legislative power but limited to legislation)
Williams v. Parrack, 83 Ariz. 227 (Ariz. 1957) (initiatives that set policy and repeal ordinances are legislative)
Saggio v. Connelly, 147 Ariz. 240 (Ariz. 1985) (posits legislation must enact a specific rule or policy)
Fritz v. City of Kingman, 191 Ariz. 432 (Ariz. 1998) (re-zoning decisions implementing general policy are legislative)