Justia Arizona Supreme Court Opinion Summaries

This case involves a dispute over the ownership of a vacant lot. Renee Dominguez holds a recorded deed to the lot, but Magdalena Rios De Dominguez claims the deed is a forgery and asserts ownership through a previously recorded deed. The primary issue is the applicability of A.R.S. § 12-524, which sets a five-year statute of limitations for quiet title actions against a party with a recorded deed who has paid property taxes for the preceding five years.The Superior Court in Maricopa County granted summary judgment in favor of Renee, ruling that even if the deed was forged, the five-year statute of limitations barred Magdalena's claim, thus conferring full title to Renee. The court also ruled that quieting title for Renee barred Magdalena’s claim for damages under A.R.S. § 33-420. The Court of Appeals affirmed the Superior Court's decision.The Supreme Court of the State of Arizona reviewed the case and held that a "recorded deed" under § 12-524 includes any deed that is facially valid, even if it is forged. Since Renee's deed was facially valid and she met the other requirements of § 12-524, the five-year statute of limitations applied. However, the court also held that Magdalena had sufficiently preserved her arguments for equitable tolling and the discovery rule, which, if successful, could make her complaint timely under § 12-524. The court vacated parts of the Court of Appeals' opinion and remanded the case for consideration of these arguments.The Supreme Court affirmed the remainder of the Court of Appeals' opinion and denied both parties' requests for attorney fees, allowing them to re-urge their requests before the appropriate court after the remand. View "DOMINGUEZ v DOMINGUEZ" on Justia Law

April Sponsel, a prosecutor at the Maricopa County Attorney’s Office (MCAO), was disciplined for her conduct in several cases. She was found to have violated multiple Arizona Rules of Professional Conduct, including competence, diligence, good faith, and conduct prejudicial to the administration of justice. The violations stemmed from her handling of cases related to an October 2020 protest, as well as other cases involving defendants Charles Walker and Richard Villa. Sponsel was accused of filing charges without sufficient evidence, failing to review available evidence, and making unsupported allegations.The disciplinary panel concluded that Sponsel violated ethical rules by not thoroughly investigating the cases before filing charges and by pursuing charges that were not supported by the evidence. The panel found that her actions caused significant harm to the defendants, including wrongful incarceration and damage to their reputations. The panel also noted that her conduct negatively impacted the integrity and morale of the MCAO.The Arizona Supreme Court reviewed the case and affirmed the panel’s findings and the two-year suspension from the practice of law. The Court agreed that Sponsel’s conduct violated the ethical rules and caused harm to the defendants and the justice system. The Court emphasized the importance of a prosecutor’s duty to seek justice rather than merely secure convictions. The Court also noted that the suspension was necessary to protect the public, deter similar misconduct, and maintain confidence in the integrity of the legal system. View "In re Sponsel" on Justia Law

The case involves the Arizona Abortion Access Act Initiative I-05-2024, which appeared on the November 5, 2024, general election ballot. The Legislative Council prepared an analysis of the initiative, which included a description of existing state law prohibiting abortions after 15 weeks of gestation, except in medical emergencies. The analysis used the term "unborn human being" to describe the existing law, which the initiative's proponents argued was not impartial and requested the term "fetus" be used instead.The Superior Court in Maricopa County ruled in favor of the initiative's proponents, finding that the term "unborn human being" was emotionally and partisanly charged, and ordered the Council to replace it with a neutral term. The Council members appealed the decision, arguing that the analysis was impartial and complied with statutory requirements.The Arizona Supreme Court reviewed the case and reversed the Superior Court's ruling. The Court held that the analysis substantially complied with the statutory requirement for impartiality by accurately describing existing law using the precise terminology found in the statute. The Court emphasized that the term "unborn human being" is used in the existing law and that the analysis provided necessary background information to voters. The Court concluded that the analysis was impartial and did not advocate for or against the initiative. The request for attorney fees and costs by the initiative's proponents was denied. View "ARIZONA FOR ABORTION ACCESS v MONTENEGRO" on Justia Law

Jose and Kirstin Aroca executed a "Note Secured by Deed of Trust" in 2007, agreeing to pay Tang Investment Company $40,000, secured by real property in Pinal County. They made interest-only payments for one year and then stopped. Tang did not initiate foreclosure or any action to enforce the debt, which remains unpaid. In 2022, the Arocas filed a suit to quiet title, claiming the Deed of Trust was invalid as the statute of limitations on the Note had expired.The Superior Court in Pinal County dismissed the Arocas' complaint, agreeing with Tang that under A.R.S. § 33-714, the Deed of Trust lien was valid until 2057. The court of appeals reversed, holding that A.R.S. § 33-714 did not extend the statute of limitations for foreclosure, which was governed by A.R.S. § 33-816 and A.R.S. § 12-548(A)(1), setting a six-year limit. The court concluded that Tang could not foreclose or initiate a trustee’s sale after 2018 and that the Arocas were entitled to quiet title under A.R.S. § 12-1104(B).The Supreme Court of Arizona reviewed the case and held that the equitable principles from Provident Mut. Bldg.-Loan Ass’n v. Schwertner do not override the statutory rights established in A.R.S. § 12-1104(B). The court determined that an action to quiet title can proceed even if the underlying debt remains unpaid, provided the statute of limitations for enforcing the debt has expired. The court reversed the Superior Court's judgment and remanded for entry of judgment in favor of the Arocas, affirming their right to quiet title. The court also vacated parts of the court of appeals' opinion but left the attorney fees award intact. Tang's request for attorney fees and costs was denied. View "AROCA v TANG INVESTMENT" on Justia Law

Giovani Fuster Melendez moved from Puerto Rico to Arizona in 2017 and became acquainted with the victim, A.G., through a church connection. In 2019, Melendez returned to his former apartment complex, encountered A.G., and fired multiple shots at him, missing each time. Melendez was taken into custody shortly after the incident. During his police interview, he was read his Miranda rights twice and initially chose not to speak. However, in a subsequent interview, he deferred answering some questions but eventually confessed to the shooting, claiming self-defense.The Superior Court in Maricopa County convicted Melendez of aggravated assault and five counts of endangerment, sentencing him to concurrent prison terms. On appeal, the Arizona Court of Appeals found that the State's references to Melendez's selective silence during his police interview violated his constitutional rights, constituting fundamental prejudicial error.The Arizona Supreme Court reviewed the case to determine if the State violated Melendez's due process rights by commenting on his post-Miranda statements and temporary deferrals during the trial. The Court held that the State could use a defendant’s post-Miranda statements and temporary deferrals for impeachment purposes if the defendant did not unambiguously invoke his Miranda rights and ultimately spoke on the substantive matters. The Court concluded that Melendez did not unequivocally invoke his right to remain silent and that his deferrals were tactical rather than an invocation of his rights. Therefore, the prosecutor's comments did not violate Melendez's due process rights. The Arizona Supreme Court affirmed Melendez's convictions and sentences and vacated the Court of Appeals' opinion. View "STATE OF ARIZONA v MELENDEZ" on Justia Law

Firefighter Robert Vande Krol filed a workers' compensation claim in January 2021, identifying his injury as brain cancer with an injury date of October 28, 2020. Vande Krol argued that the 2021 statute, which eased the burden on firefighters to establish a statutory presumption for certain diseases, should apply to his claim. This statute became effective nearly a year after his injury and eight months after he filed his claim.The Industrial Commission of Arizona (ICA) initially reviewed the case, and an Administrative Law Judge (ALJ) held an evidentiary hearing. The ALJ determined that the 2017 statute applied, as it was in effect when Vande Krol received his diagnosis and filed his claim. The ALJ concluded that Vande Krol did not meet the requirements of the 2017 statute, specifically failing to link his cancer to a known carcinogen related to his work. Consequently, the ALJ denied his claim for compensation.The Arizona Court of Appeals disagreed with the ALJ, ruling that the 2021 statute should apply because it became effective before the evidentiary hearing. The court set aside the ALJ's decision, concluding that the statutory presumption was procedural and did not result in an impermissible retroactive application.The Supreme Court of the State of Arizona reviewed the case and concluded that the 2021 statute does not apply to Vande Krol’s claim. The court held that the 2021 statute is substantive in nature and does not contain an express declaration of retroactivity. Therefore, the substantive right of the employer and insurer vested at the time Vande Krol filed his claim, making the 2017 statute applicable. The court vacated the Court of Appeals' opinion and remanded the case for further proceedings consistent with its opinion. View "VANDE KROL v SUPERSTITION/BENCHMARK" on Justia Law

A constable, Deborah Martinez-Garibay, was fatally shot while attempting to serve a writ of restitution to a tenant who had threatened a resident with a gun. The tenant also killed Angela Fox, who was accompanying Garibay, and another individual before taking his own life. Angela's surviving spouse, William Fox, filed a wrongful death lawsuit against Garibay's spouse, Pima County, and the Arizona Constable Ethics, Standards and Training Board, alleging negligence and gross negligence on Garibay's part.The Superior Court of Pima County denied Garibay's spouse's motion for judgment on the pleadings, which argued that Garibay was entitled to judicial immunity and owed no duty to Angela. The Court of Appeals accepted special action jurisdiction and reversed the Superior Court's decision, holding that Garibay was judicially immune from liability as her actions did not constitute "misconduct" under A.R.S. § 11-449.The Supreme Court of the State of Arizona reviewed the case to determine whether the common law doctrine of judicial immunity shields constables from liability under A.R.S. § 11-449. The court held that § 11-449 limits, rather than abrogates, judicial immunity. It concluded that a constable who engages in "misconduct" in the service or execution of a writ is subject to liability. The court defined "misconduct" as an intentional violation of an applicable rule, standard, or norm, rather than mere negligence or gross negligence.The court found that Fox's complaint did not allege that Garibay engaged in "misconduct" as defined by the statute, but rather that she was negligent or grossly negligent. Therefore, the court concluded that Garibay was entitled to judicial immunity and reversed the lower court's decision, remanding the case for further proceedings consistent with its opinion. View "GARIBAY v FOX" on Justia Law

Roxanne Perez was shopping at a Circle K convenience store when she tripped over a store display of bottled water and injured herself. She sued Circle K for negligence and premises liability, claiming that the store had notice of the dangerous condition and failed to remedy it or warn her. Perez argued that Circle K owed her a duty of care as a business invitee to keep the store in a reasonably safe condition.The Superior Court in Maricopa County granted summary judgment in favor of Circle K, finding that the store did not owe Perez a duty because the water display was an open and obvious condition. The court reasoned that Perez would have seen the display had she looked down, and therefore, it did not pose an unreasonable risk of harm. The Court of Appeals, Division One, affirmed the Superior Court's decision in a divided opinion.The Supreme Court of the State of Arizona reviewed the case and concluded that whether the store display was an unreasonably dangerous condition is not relevant to the issue of duty. The court held that Circle K owed Perez a duty of care as a business invitee to keep the store in a reasonably safe condition. The determination of whether the display was unreasonably dangerous pertains to whether Circle K breached its duty, not whether a duty existed. The Supreme Court vacated the Court of Appeals' opinion in part, reversed the Superior Court's summary judgment, and remanded the case for further proceedings. View "Perez v. Circle K" on Justia Law

Mother conceived M.N. with Father in summer 2020. Before M.N. was born, Mother and her boyfriend initiated adoption proceedings without informing the adoption agency about Father. M.N. was born on March 23, 2021, and Father requested a DNA test at the hospital. In April 2021, Mother and her boyfriend signed adoption consent forms, and the adoption agency petitioned for termination of parental rights. After being identified as a potential father, Father was served notice of the adoption and filed a paternity action within the required timeframe. Genetic testing confirmed Father as the biological father.The juvenile court terminated Father’s parental rights, finding he failed to file with the putative fathers registry. The court of appeals reversed and remanded, concluding the juvenile court improperly terminated Father’s rights under § 8-533(B)(6) without considering his rights as a potential father under § 8-106. The court of appeals held that genetic testing established Father as a presumed legal father, exempting him from filing with the putative fathers registry.The Supreme Court of Arizona reviewed the case to determine if a potential father served with a § 8-106 notice must file a notice of a claim of paternity with the putative fathers registry under § 8-106.01. The court held that a potential father identified and served notice under § 8-106(G) is not required to file with the putative fathers registry. The court emphasized that the potential fathers statute and the putative fathers statute address separate classifications of fathers, each with distinct rights and obligations. The court vacated parts of the court of appeals’ opinion, reversed the juvenile court’s termination order, and remanded for further proceedings. View "IN RE TERM OF PARENTAL RIGHTS AS TO M.N." on Justia Law

San Diego Gas & Electric Company (SDG&E) owns an interstate electric transmission line running from Arizona to California. The Arizona Department of Revenue (ADOR) is responsible for valuing SDG&E's property in Arizona for tax purposes. In 2020, SDG&E reported a net "original plant in service" valuation of $48,817,396 and a net "related accumulated provision for depreciation" amount of $51,446,397, resulting in a negative valuation of $2,629,001. ADOR disagreed with this calculation and determined a different accumulated depreciation amount, resulting in a positive valuation.The Arizona Tax Court granted summary judgment in favor of SDG&E, finding that their valuation correctly followed the statutory requirements. ADOR appealed, and the Arizona Court of Appeals reversed the Tax Court's decision, holding that the statute did not permit a negative valuation for a plant in service and that accumulated depreciation could not reduce the full cash value to a negative number. The Court of Appeals remanded the case for further proceedings.The Arizona Supreme Court reviewed the case and held that the calculation prescribed by the statute for determining a reduced plant in service cost does not preclude a negative valuation. The Court found that the statutory language did not limit the reduction of the original plant in service cost by accumulated depreciation to a non-negative number. Additionally, the Court clarified that a negative valuation for one component, when summed with other component valuations, reduces the overall full cash value but does not "offset" the valuation of other components. The Supreme Court vacated the relevant portions of the Court of Appeals' opinion and affirmed the Tax Court's grant of summary judgment in favor of SDG&E. View "San Diego Gas & Electric Co. v. Arizona Department of Revenue" on Justia Law