Last Rites for Clean Elections

In Arizona Citizens Clean Elections Commission v. Brain, the Arizona Supreme Court ruled that voters who passed a 1998 voter initiative did not intend to cap contribution limits at the 1998 levels. The Court held that the Arizona State Legislature could adjust the campaign contribution limits through a simple majority vote. This Note will cover the history behind Arizona campaign finance law, explore the ramifications of the Brain decision, and predict the slow demise of the Arizona Clean Elections scheme.