- The city failed to follow its own procedures for validating additional petition signatures submitted for renaming a street in Portland to Cesar E Chavez Boulevard. When a second batch of signatures was submitted, the city did not draw a new random sample from the combined batches as its policies required. - The city made no effort to determine if any non-registered voter signatures belonged to legal US residents, as required by city code. - Using the proper statistical method of combining the two batches, the estimated total valid signatures is less than the 2,500 required. Given the procedural errors, the only way to be certain is to fully validate all signatures.