Justia Arizona Supreme Court Opinion Summaries

Charles Stenz suffered a workplace injury. His employer’s insurance carrier, Pinnacle Risk Management, accepted Stenz’s claim and paid the benefits. Stenz subsequently died, and his widow, Elizabeth Stenz, filed a claim for death benefits. An administrative law judge (ALJ) upheld the denial. The court of appeals set aside the award. The ALJ eventually awarded death benefits and, almost four years after Elizabeth filed her claim, entered a final order affirming the award. Pinnacle paid the benefits dating back to Stenz’s death but did not pay interest on the unpaid benefits. The ALJ concluded that no interest was owed on the death benefit before the award became final. The court of appeals set this ruling aside, concluding that the claim was liquidated as of the date Pinnacle received notice of it. The Supreme Court vacated the opinion of the court of appeals and set aside the ALJ’s award, holding that a claim for death benefits filed pursuant to Ariz. Rev. Stat. 23-1046 is a liquidated claim, and interest is owed on the claim from the date on which the carrier receives notice that a survivor has filed a claim with the Industrial Commission. View "Stenz v. Indus. Comm’n of Ariz." on Justia Law

Linda Bell was injured at her job and underwent surgery for her injury seventeen months later. Bell requested temporary partial disability (TPD) compensation to reimburse her for the sick leave and vacation time she had used following her injury and before her surgery. The Industrial Commission of Arizona (ICA) denied the request on the ground that Bell did not had not taken time off work during the time period for which benefits were requested and that she did not miss any period of time over one week. The court of appeals affirmed on the ground that Bell failed to prove she had satisfied the waiting period created by Ariz. Rev. Stat. 23-1062(B). The Supreme Court vacated the court of appeals’ opinion and set aside the ICA award, holding (1) the waiting period for compensation set forth in section 23-1062(B) applies to claims for all types of disability including both TPD benefits and temporary total disability (TTD) benefits; and (2) section 23-1062(B) does not require proof of an initial period of TTD but does require proof of seven consecutive calendar days of some type of work-related disability before an injured employee becomes entitled to compensation for any type of disability. View "Bell v. Indus. Comm’n of Ariz." on Justia Law

At issue in this case was whether a juvenile court can delegate discretion to the Arizona Department of Economic Security (ADES) to return a dependent child to his or her parents without first determining that return is in the child’s best interests. The juvenile court concluded that ADES has the discretion to determine when it serves a dependent child’s best interests to be returned to the child’s parent or guardian. The Supreme Court vacated the juvenile court’s order, holding (1) a juvenile court must specifically determine that return of a dependent child to his or her parents is in the child’s best interests before ordering the return; and (2) the juvenile court in this case erred by granting discretion to ADES to place dependent children with their parents without a prior judicial determination that reunification was in the children’s best interests. View "Alexander M. v. Hon. Lisa Abrams" on Justia Law

In 1985, the Arizona Legislature established the Elected Officials’ Retirement Plan (“Plan”), which provides pension benefits for elected officials, including judges. Ariz. Rev. Stat. 38-818 establishes a formula for calculating pension benefit increased for retired members of the Plan. In 2011, the Legislature enacted S.B. 1609, which modified the formula set forth in section 38-818. Two retired judges, on behalf of themselves and as representatives of a class of retired Plan members and beneficiaries, sued the Plan and its board members, alleging that S.B. 1609 violated Ariz. Const. art. 29, 1(C). The trial court ruled in favor of Plaintiffs, concluding that S.B. 1609 violated Article 29, 1(C)’s prohibition against the diminishment or impairment of public retirement system benefits. The Supreme Court affirmed, holding that because the statute diminished and impaired the Plan’s retired members’ benefits, it violated the Pension Clause of Article 29, 1(C). View "Fields v. Elected Officials’ Ret. Plan" on Justia Law

The State of Arizona filed an interlocutory appeal from an order issued in the general stream adjudications of the Gila River System and Source and the Little Colorado System and Source. At issue was whether federal water rights were impliedly reserved on lands granted by the United States government to the State of Arizona to support education and other public institutions (State Trust Lands). The Supreme Court accepted review and affirmed the superior court's ruling that there was no withdrawal, no reservation for a federal purpose, and no congressional intent to reserve water rights for the State Trust Lands. View "In re Water Rights to Gila / Little Colorado" on Justia Law

Plaintiffs leased state trust land and owned all structures and improvements on the land. Under the terms of the lease, the improvements that existed on the land would become the state's property upon lease termination. After the leases were entered into, the legislature created a property tax classification ("Class Nine") in which property was taxed at a lower rate than that applicable to commercial property. For certain years, Maricopa County classified the improvements under the classification applicable to general commercial property and taxed Plaintiffs accordingly. The State Board of Equalization denied Plaintiffs' request for Class Nine classification. Plaintiffs then filed a declaratory judgment action in the tax court. The tax court granted summary judgment for the County based on Plaintiffs' failure to meet the requirements of Ariz. Rev. Stat. 42-12009(A)(1)(a), which provides that improvements on land leased from the state qualify for a reduced ad valorem tax rate if they become the property of the state on termination of the leasehold interest in the property. The Supreme Court remanded, holding that section 42-12009(A)(1)(a) applies when, at the time of taxation, improvements exist on the land that, under the terms of the lease, would become the state's property upon lease termination. View "CNL Hotels & Resorts, Inc. v. Maricopa County" on Justia Law

Jacob Braden, an adult with developmental disabilities, died as a result of injuries suffered while residing at an Arizona Integrated Residential and Educational Services (AIRES) facility. AIRES is a licensed private corporation that contracts with the Arizona Department of Economic Security's Division of Developmental Disabilities. Jacob's estate sued the State, alleging a statutory claim under the Adult Protective Services Act (APSA) for abuse and neglect. The trial court granted summary judgment for the State, finding it was not a proper defendant under Ariz. Rev. Stat. 46-455, which permits an action under APSA against a "person" or an "enterprise." The court of appeals reversed, concluding that the State was not exempt from liability under section 46-455. The Supreme Court vacated the court of appeals and affirmed the superior court after applying the rules of statutory construction to section 46-455, concluding that the State was not liable under APSA because the legislature did not intend to include the State in its expressly enumerated list of potential APSA defendants. View "Estate of Braden v. State" on Justia Law