1

 Case number 20150261.

This opinion is subject to revision before final

publication in the Pacific Reporter

2015 UT 86

IN THE

SUPREME COURT OF THE STATE OF UTAH

STEPHANIE GRICIUS, KAMME EDSBERG, MELISSA BRADLEY, 

and COLBY CURTIS,

Petitioners,

v.

SPENCER J. COX, 

Lieutenant Governor,

Respondent.

No. 20150581

Filed September 23, 2015

Attorneys:

Stephanie Gricius, Kamme Edsberg, Melissa Bradley, 

Colby Curtis, Salt Lake City, pro se

Sean D. Reyes, Att’y Gen., Thom D. Roberts, Asst. Att’y Gen., 

Salt Lake City, for respondent

PER CURIAM:

¶1 This matter is before the court on a petition for extraordinary

relief filed by Stephanie Gricius, Kamme Edsberg, Melissa Bradley,

and Colby Curtis. Previously, a similar petition was filed by Fred C.

Cox,1 but we determined he lacked standing because he had not

identified himself as one of the prospective sponsors of the proposed

referendum petition described by his petition.

¶2 This petition has been filed by four of the prospective

sponsors of that referendum petition. The petition pertains to a

contemplated referendum for the repeal of HB 454, entitled “Prison

Development Amendments,” enacted by the Legislature during its

2015 General Session, which ended on March 12, 2015. It asserts that

the group of sponsors prepared a referendum application and

“attempted to submit their Application on March 27, 2015, but

[were] refused and denied that opportunity by the Utah [Lieutenant]

Governors’ Election Office, based on the [five-day] deadline found

in Utah Code 20A-7-302.”
GRICIUS v. COX

Opinion of the Court

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 Previously, Mr. Cox’s petition also asserted that an enrolled

copy of the bill often will not be available for several days after the

end of the legislative session. This petition also includes a cursory

referenced to the unavailability of an enrolled copy but has not

proffered any argument that a delay in the availability of an enrolled

copy of the bill separately prevented the sponsors from complying

with the statutory application requirements.

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¶3 Section 20A-7-302 states:

(1) Persons wishing to circulate a referendum

petition shall file an application with the

lieutenant governor within five calendar days

after the end of the legislative session at which

the law passed.

(2) The application shall contain:

(a) the name and residence address of at least

five sponsors of the referendum petition;

(b) a certification indicating that each of the

sponsors:

(i) is a voter; and

(ii) has voted in a regular general election

in Utah within the last three years;

(c) the signature of each of the sponsors,

attested to by a notary public; and

(d) a copy of the law.

The petition implies that the five-day deadline is unconstitutional

because, as a practical matter, referenda sponsors cannot comply. It

notes the period for the Governor to review a bill passed by the

Legislature exceeds the five-day period, and it assumes the term

“law,” as employed by section 20A-7-302, must refer to a bill that has

been signed by the Governor or not vetoed within the period he is

afforded to review the bill.2

 The petition does not include any

affidavits or other documentation in support of its factual allegations

except a copy of an application for a referendum that was prepared

by the sponsors.

¶4 The Lieutenant Governor filed a response on August 6, 2015,

and an affidavit from Mark Thomas, the Lieutenant Governor’s

Chief of Staff and Director of Elections, which stated that his office

“ha[d] not refused to accept or file the referendum petition,” that it
Cite as: 2015 UT 86

Opinion of the Court

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 In connection with our consideration of the prior petition, we

requested that Mr. Cox and the Lieutenant Governor file supplemental pleadings addressing the standing issue that we ultimately

deemed determinative. We also asked the parties to address the

question of

what form of the ‘copy of the law’ must be attached to

an application for a referendum petition under Utah

Code § 20A-7-302(2)(d); and, if the term ‘law’ is

construed to mean ‘a bill passed by the Legislature,’

how does an applicant comply with that requirement

if a copy of the enrolled version of the bill is not

available within the five-day limit specified by Section

20A-7-302(1)?

4

 This is because our only means of resolving disputed material

facts in the first instance and in conformity with the requirements of

due process is to make a referral to a special master; and we

undertake those referrals only in exceedingly rare circumstances.

Additionally, there is some question as to whether this court should

consider any argument pertaining to the requirement that the law

challenged by the referendum be attached to the referendum

application. That argument has not been clearly stated in the

petition. A petitioner has the burden of clearly presenting all

arguments within the original petition, may not present new

argument that could have been raised in the original petition in a

reply to a response, and is required to submit pleadings in a proper

form.

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“received at least two phone[ ] calls toward the end of March 2015

with regard to the time to file an application for a referendum,” and

that “on both occasions the caller was advised that under the statute

the application must be filed within 5 days of the end of the

legislative session.”3

¶5 When an appellate court considers a petition for

extraordinary relief without any record generated by prior litigation

or other official proceedings, it ordinarily may grant relief only if

that relief is based on allegations properly supported by affidavit or

other reliable documentation.4

 SeeCarpenter v. Riverton City, 2004 UT

68, ¶ 5, 103 P.3d 127; Fundamentalist Church of Jesus Christ of LatterDay Saints v. Horne, 2012 UT 66,¶ 41, 289 P.3d 502. The petition fails

to satisfy the requirement of demonstrating that its allegations are

supported by affidavit .
GRICIUS v. COX

Opinion of the Court

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 “A bill passed by the Legislature” would perhaps be more

precise language than “law.” Nonetheless, in the context of the

statute, the term “law” provides adequate notice of the form and

status of the matters to which the statute refers.

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¶6 But even if we accepted the petition’s factual allegations, we

would not be persuaded that it has established a constitutional

violation because it has not described any circumstances that

actually prevented the sponsors from filing their application within

the specified deadline. In that regard, it appears the petition

depends on the assumption that the use of the term “law” within

section 20A-7-302 cannot be deemed to refer to a bill passed by the

Legislature, or that the term is so ambiguous as to preclude

compliance. While it is true that the term “law” employed in

isolation ordinarily may refer to a presently effective legal mandate,

such a definition clearly is inapplicable when the context provided

by other text within section 20A-7-302 is considered. The reference

to a “law” within the provision establishing the five-day deadline

cannot be interpreted to mean a legislative edict that is presently

effective or that has been approved or not vetoed by the Governor

because the deadline also clearly and explicitly references the end of

the legislative session as the starting point for calculating the

deadline. Thus, there is no reasonable interpretation of the term

“law” that could mean anything other than a bill passed by the

Legislature in whatever form it exists at the time the legislative

session ends. And, even assuming a reasonable person could be

confused by the use of the term “law,” the specification of the

deadline at a minimum should prompt that person to inquire about

available means of compliance before the expiration of that

deadline.5

 Yet, in this case, there is no allegation that any inquiry

was directed to the Lieutenant Governor’s office prior to March 27,

2015, fifteen days after the end of the legislative session.

¶7 Additionally, we can discern no basis for perceiving an

infringement of constitutional rights arising from the possibility that

the sponsors’ initial efforts would be rendered moot by a veto that

would have provided them with the same outcome they intended to

seek through the referendum. The remedies of a veto and a

referendum are independent and complementary in nature.

Opponents of a bill passed by the Legislature are free to lobby the

Governor at the same time they embark on the path of seeking

repeal through the voice of the people, and we cannot see how they

could claim any disappointment, let alone any violation of their
Cite as: 2015 UT 86

Opinion of the Court

6

 In his response to our prior inquiry, the Lieutenant Governor

asserted that a copy of the bill passed by the Legislature is available

on the Legislature’s website within five days of the date of the end

of the session.

7

 Insofar as the petition implies an argument based on the

sponsors’ inability to know the precise details of the bill until they

receive an enrolled copy, we are not persuaded. Sponsors who have

complied with the relatively simple and straightforward requirements of the application process are not obligated to move forward

with the much more arduous task of obtaining and submitting

signatures on a referendum if further review of the minute details of

a passed bill persuades them to abandon the effort.

8

 A statutory amendment to clarify the manner in which referenda sponsors may satisfy the statutory requirement to attach a copy

of the “law” might be appropriate, but we leave that to the judgment

of the Legislature.

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constitutional rights, if the Governor’s exercise of his prerogative as

to the former relieves them of the burden of undertaking the latter.

¶8 Finally, insofar as the petition properly can be construed as

timely and adequately raising an issue regarding the form of the

“law” that the statute requires the sponsors to attach to the

application, see supra ¶ 4 n.3, its claim of ambiguity may carry more

weight. If the statute may be construed as requiring an enrolled

copy of the bill, and such a copy is not available before the passage

of the deadline for filing the application, then sponsors would have

no practical means of complying with the statute. But again, in that

context the statute can be construed only as requiring whatever form

of the bill the sponsors reasonably can obtain for attachment to a

timely application.6

 And, to the extent sponsors of a referendum

application have made a good faith effort to comply with the statute

by attaching a copy of the most recent version of the bill that is

available to them, the Lieutenant Governor clearly cannot refuse the

application.7

 We also do not read the statute to preclude the

Lieutenant Governor from supplying a more proper or accurate

copy of the bill for purposes of circulation for signature. Indeed,

such a substitution might be appropriate, or even necessary, in some

circumstances.8

¶9 In sum, we conclude that Petitioners have not provided us

with a sound basis for declaring section 20A-7-302 of the Utah Code

unconstitutional on its face or as applied to the facts as they have
GRICIUS v. COX

Opinion of the Court

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sufficiently alleged. Accordingly, we decline to grant the relief they

request.