An informal AGO Opinion issued 8/9/1960, signed by Assistant Attorney General Jane Dowdle Smith and addressed to Maryan E. Reynolds, states:
“A primary election is not a special election… A primary election is not a general election… Accordingly, unless there is to be held a special election which is authorized by statute… the proposition must be placed upon the ballot at the general election.”
This conclusion is supported by AGO 59-60 No. 133, which finds that primary elections are neither general elections nor special elections for the purpose of setting school district levies.