## Facts

- William L. Hutchinson ran for Salt Lake County Commissioner.
- Salt Lake County charged Hutchinson with two misdemeanor violations of a county campaign-finance disclosure ordinance (Salt Lake County Rev. Ord. § 1-10-4).
- Count 1 alleged failure to report the name and address of a $6,000 campaign contributor.
- Count 2 alleged failure to file supplemental disclosures reporting discharge of campaign debts and obligations.
- The ordinance required candidates or their committees to file full, correct, itemized statements of monies and things of value received and expended on county-provided forms, and made noncompliance a misdemeanor.
- Hutchinson moved to dismiss, arguing the county lacked constitutional and statutory authority (including under Utah Code Ann. § 17-5-77) to enact the ordinance and that state campaign-finance statutes preempted local regulation.
- The city court dismissed the complaint; the district court affirmed; the State appealed.

## Issues

1. Whether Salt Lake County had statutory authority, including under Utah Code Ann. § 17-5-77, to enact a campaign-contribution disclosure ordinance applicable to county candidates.
2. Whether state campaign-finance statutes preempted local campaign-disclosure regulation for county elections, rendering the ordinance invalid.

## Decision

- The Utah Supreme Court reversed and upheld the ordinance.
- The court held the county had authority under the legislature’s broad general-welfare grant in Utah Code Ann. § 17-5-77 to adopt the disclosure requirements.
- The court held state campaign-finance statutes did not preempt local regulation of disclosure for local elections because the state scheme did not occupy the field and the ordinance did not conflict with state law.
- The case was remanded for further proceedings consistent with the opinion, permitting reinstatement of the charges.

## Legal Principles

- A legislative “general welfare” grant to counties authorizes ordinances reasonably related to local public welfare, absent a prohibition or conflict with state law.
- County powers under broad statutory grants are not limited to enumerated subjects if the ordinance is reasonably connected to the granted purpose.
- Preemption requires clear legislative intent to occupy the field or a direct conflict between local and state law; complementary local regulation may stand when state law does not comprehensively regulate the local subject.
- In Utah, local governments may exercise the full scope of legislatively granted powers unless the exercise directly conflicts with state law.

## Conclusion

The Utah Supreme Court sustained Salt Lake County’s campaign-disclosure ordinance as a valid exercise of county general-welfare authority and rejected preemption because state campaign-finance statutes did not comprehensively regulate local election disclosures or conflict with the county’s requirements.


State v. Hutchinson, 624 P.2d 1116 (Utah 1980)