In 1991, Arizona faced a constitutional crisis when no candidate for governor achieved a majority in the 1990 general election. The United States state was forced to hold its first-ever runoff election after a legal battle over the interpretation of the state’s “majority-vote” requirement.
TLDR: Following the 1990 general election, Arizona entered a constitutional vacuum when neither Fife Symington nor Terry Goddard secured over 50% of the vote. The resulting 1991 runoff election, mandated by a strict constitutional provision, paralyzed state leadership for months and eventually led voters to abolish the majority-win requirement.
The 1990 general election in Arizona was intended to provide a fresh start for a state still reeling from the impeachment and removal of Governor Evan Mecham just two years prior. Instead, it produced a constitutional deadlock that left the executive branch in a state of suspended animation for months. The crisis centered on a specific provision in the Arizona Constitution that required a candidate for governor to receive a “majority of all votes cast” to be declared the winner, a relic of the state’s Progressive-era founding documents.
When the ballots were tallied in November 1990, Republican real estate developer Fife Symington held a narrow lead over Democrat Terry Goddard, the former mayor of Phoenix. However, the math was unforgiving. Symington garnered only 49.7 percent of the vote, while Goddard took 49.2 percent. A third-party candidate, Max Dunlap—who was at the time a figure of significant notoriety due to his later-overturned and then reinstated conviction in the murder of reporter Don Bolles—received enough votes to prevent either major candidate from reaching the 50 percent plus one threshold.
This mathematical shortfall triggered an immediate legal and political crisis. Arizona had never before faced a situation where the “majority” requirement was not met in a gubernatorial race. While plurality wins were the standard in almost every other state, Arizona’s strict constitutional language left no room for interpretation. The state was effectively without a governor-elect, and the transition of power, usually a routine matter of democratic stability, was abruptly halted.
Incumbent Governor Rose Mofford, who had assumed office following Mecham’s removal, found herself in an awkward constitutional position. Her term was technically over, yet the law required her to remain in office until a successor was “qualified.” For several months, Mofford presided over a “lame duck” administration that lacked a clear mandate. This period of uncertainty paralyzed the state’s political infrastructure, as department heads and policy advisors were unsure of their future roles or the direction of the next administration.
The legal battle moved swiftly to the Arizona Supreme Court. The justices were tasked with determining if the “majority” requirement was absolute or if the candidate with the most votes could be seated. The court affirmed that a runoff election was the only constitutional remedy. Consequently, the state legislature was forced to scramble to set a date and provide emergency funding for a special election. The runoff was eventually scheduled for February 26, 1991, creating a massive gap in executive leadership.
This delay meant that for the first two months of the 1991 legislative session, the state lacked a governor with a fresh electoral mandate to propose a budget or set a policy agenda. The runoff campaign itself was grueling and expensive, further exhausting a state electorate that had grown weary of political instability. Symington eventually won the February contest with approximately 52 percent of the vote. He was inaugurated in early March, nearly four months after the general election.
The 1991 crisis served as a catalyst for immediate structural reform. Recognizing that the majority requirement could lead to perpetual instability, especially in three-way races, the Arizona legislature proposed a constitutional amendment to prevent a recurrence. In 1992, Arizona voters approved Proposition 100, which changed the requirement for winning the governorship from a majority to a plurality. This reform ensured that the candidate with the most votes would win regardless of the percentage, aligning Arizona with the electoral practices of most other United States jurisdictions. The event remains a landmark case in Western state constitutional law, illustrating the tension between the desire for a clear mandate and the practical need for a functional, continuous government.
Lila Hayes serves as a Staff Writer for Just Right News, where she anchors the “Courts, Law, and Constitutional Order” beat. Her work is defined by a steadfast commitment to the foundational principles of the American republic and a rigorous defense of the legal frameworks that ensure national stability. As a primary voice for the outlet, she provides readers with a clear-eyed analysis of the judiciary, focusing on the importance of originalism and the preservation of the separation of powers.
Lila’s perspective was forged in the American heartland. Raised in St. Louis, Missouri, she grew up in a Hispanic household where the values of hard work, faith, and respect for the law were paramount. Her upbringing instilled in her a deep appreciation for the American Dream and the legal protections that make it possible. This Missouri background remains a cornerstone of her reporting, providing a grounded, common-sense counter-narrative to the often-insular legal circles of the coastal elite. She understands that the decisions made in high-court chambers have real-world consequences for families and small business owners across the country.
At Just Right News, Lila has become widely recognized for her signature feature series, “The Rulebook of Power.” In this ongoing project, she delves into the mechanics of the federal government, examining how administrative overreach and judicial activism can threaten the delicate balance of the Constitution. She approaches her beat with the tenacity of a veteran journalist and the precision of a legal scholar, consistently advocating for a judiciary that interprets the law as written rather than legislating from the bench. For Lila, the Constitution is not a “living” document subject to the whims of modern social trends; it is a fixed standard that ensures the government remains the servant of the people, not their master.
Now based in Philadelphia, Pennsylvania, Lila finds herself at the very epicenter of American constitutional history. Living and working in the city where the Founders drafted the documents she defends daily provides a constant source of inspiration. The historic halls and landmarks of Philadelphia serve as a daily reminder of the high stakes involved in her reporting. Her presence in the city allows her to bridge the gap between the historical intent of the law and its contemporary application, ensuring that the legacy of the Founding Fathers remains central to the national conversation.
Throughout her career, Lila has remained dedicated to the idea that a free society requires an informed citizenry and a transparent legal system. Her reporting is more than just a collection of headlines; it is a defense of the constitutional order that has sustained the nation for over two centuries. By focusing on the “Rulebook of Power,” she ensures that her readers understand not just what is happening in the courtrooms, but why those decisions matter for the future of American liberty. Lila Hayes continues to be a vital voice for those who believe that the law should be a shield for the citizen and a constraint on the state.