Phillips v. City of Whitefish: Legislative or Administrative, That Is the Referendum Question
Under Montana law, the power of citizens to repeal local government resolutions by referendum extends only to legislative acts. In Phillips v. City of Whitefish, the Montana Supreme Court held that a resolution amending an interlocal agreement between the City of Whitefish and Flathead County was an administrative act, despite the legislative nature of the original interlocal agreement.
Michelle Tafoya, Case Note, Phillips v. City of Whitefish: Legislative or Administrative, That Is the Referendum Question, 76 Mont. L. Rev. Online 77, https://scholarship.law.umt.edu/mlr_online/vol76/iss1/9.