McNamara v. Citizens Protecting Tax Payers

OPINION

DOWNIE, Judge.

¶ 1 The dispositive issue in this appeal is whether qualified electors may maintain a private cause of action based on alleged violations of Arizona Revised Statutes (“A.R.S.”) section 16-915.01 (disposal and use of surplus monies held by political committees). We conclude no such private right of action exists and therefore affirm the superior court’s dismissal of the complaint filed by Jane McNamara, Kim Rosenthal, and Madeleine Kesselman (“Appellants”).

FACTS AND PROCEDURAL HISTORY

¶ 2 Phoenix City Councilman Sal DiCiccio became the target of a recall effort in 2011.…