Justia Arizona Supreme Court Opinion Summaries

The case involves Sherold D. Roaf, who was rear-ended by Francisco Ortiz, an employee of Medstar. Roaf sued Ortiz for negligence and Medstar for both vicarious liability for Ortiz's negligent driving and direct liability for Medstar's negligent hiring, supervision, and retention of Ortiz. Roaf sought compensatory and economic damages but did not seek punitive damages. Medstar admitted liability for the incident but did not move to dismiss the negligent hiring claim. Instead, it sought to prevent Roaf from introducing Ortiz’s personnel record and driving history, arguing that such evidence would be irrelevant and could improperly influence the jury. The trial court denied the motion, allowing Roaf to pursue both theories of liability.The Superior Court in Maricopa County allowed the case to proceed to trial, where Roaf's counsel introduced evidence of Ortiz's driving record and Medstar's hiring policy. The jury found Roaf's full damages to be $4.625 million, allocating 40% fault to Ortiz and 60% to Medstar. Medstar moved for a new trial, arguing that the negligent hiring claim was superfluous and had allowed Roaf to put prejudicial evidence before the jury. The court denied the motion, finding that the evidence of Ortiz’s driving history had no unfair influence and that the damage award was supported by other evidence.The Court of Appeals upheld the trial court's decision, agreeing that the jury’s award was appropriate based on the evidence and that Medstar failed to show that the trial court committed prejudicial error by allowing the separate claims of negligent hiring and vicarious liability to go to the jury.However, the Supreme Court of the State of Arizona reversed the lower courts' decisions. The Supreme Court held that because Medstar admitted liability, it was wholly responsible for Roaf’s damages. Therefore, evidence of liability relating to the negligent hiring claim should have been precluded. The court also found that Medstar suffered prejudice because of the erroneous admission of Ortiz’s personnel record and driving history. The case was remanded to the trial court for a new trial. View "ROAF v REBUCK CONSULTING" on Justia Law

This case involves a dispute over jurisdiction in a divorce proceeding between Maria Del Carmen Rendon Quijada and Julian Javier Pimienta Dominguez. The couple, originally from Mexico, moved to the U.S. in 2007. Pimienta held a TN visa, allowing him to work temporarily in the U.S., while Rendon held a TD visa, reserved for spouses and minor children of TN visa holders. Rendon's TD visa expired in March 2020, and she began seeking lawful permanent resident status in December 2020. In May 2022, Rendon filed for divorce in Arizona. Pimienta argued that Rendon could not establish domicile in Arizona due to her expired TD visa, which precludes her from intending to remain in the state indefinitely. The trial court agreed and dismissed the case.The court of appeals reversed the decision, holding that Rendon's TD visa did not prevent her from establishing a U.S. domicile, as she had begun seeking lawful permanent resident status. The court concluded that federal immigration law did not preempt Arizona jurisdiction over the dissolution proceeding.The Supreme Court of Arizona disagreed with the lower courts' focus on federal immigration law. It held that the question was not whether federal immigration law divested Arizona courts of jurisdiction over a divorce sought by an expired TD visa holder, but whether the visa holder could meet the domicile requirements under Arizona law. The court concluded that federal immigration law did not prevent Rendon from establishing domicile in Arizona, and thus, the state courts had jurisdiction over the divorce proceeding. The court vacated the court of appeals' opinion, reversed the trial court's decision, and remanded the case for further proceedings. View "IN RE THE MARRIAGE OF QUIJADA/DOMINGUEZ" on Justia Law

The case revolves around Kevin Dunbar, who was convicted of multiple felonies. Dunbar requested to represent himself during the final stages of his resentencing, but the trial court denied his request. Dunbar appealed this decision, arguing that his right to self-representation had been violated. The court of appeals agreed with Dunbar, concluding that the trial court's denial constituted structural error and remanded the case back to the trial court for reconsideration of Dunbar's request.Previously, the court of appeals had upheld Dunbar's convictions but remanded for resentencing on different grounds. The court had found that Dunbar had forfeited his right to self-representation due to his inconsistent positions and his signed waiver of the right to self-representation.The Supreme Court of Arizona was tasked with deciding whether the denial of the right to self-representation at sentencing is subject to harmless error or structural error review. The court held that erroneous denials of the right to self-representation at sentencing constitute structural error. However, the court also clarified that not all denials of self-representation requests are erroneous and provided guidance on the analysis a trial court must employ in determining whether it should grant a defendant’s untimely self-representation request.The court vacated parts of the court of appeals’ decision and remanded the case back to the trial court for reconsideration of Dunbar's request to represent himself. The trial court was instructed to consider whether denying Dunbar's request would substantially undermine his right to present his case at sentencing. If the trial court determines Dunbar's motion should have been granted, structural error has occurred, and Dunbar is entitled to resentencing. If the trial court again determines that Dunbar's motion should not have been granted, Dunbar's sentences stand. View "STATE OF ARIZONA v DUNBAR" on Justia Law

The case revolves around the issue of whether reimbursements paid to a hotel for a loyalty program member’s complimentary stay constitute gross income for purposes of Arizona’s transaction privilege tax (TPT). The hotel in question, Dove Mountain, participates in the Marriott Rewards Program. As part of the program, Dove Mountain and other participating hotels fund the program's marketing efforts by paying a percentage of room revenues and providing rooms for complimentary stays to program members. When a member redeems points for a complimentary stay at Dove Mountain, Marriott Rewards issues a reimbursement payment to the hotel.The Arizona Department of Revenue (ADOR) denied Dove Mountain's request for a refund of TPT paid on certain reimbursements between 2012 and 2016. Dove Mountain appealed ADOR’s decision to the tax court, arguing that the reimbursements were part of a rewards program not subject to TPT. The tax court concluded that Dove Mountain was not eligible for a refund and entered judgment for ADOR. The court of appeals affirmed the tax court's decision, holding that the reimbursements fell within the statutory definitions of gross receipts and gross income and were subject to TPT.The Supreme Court of the State of Arizona affirmed the lower courts' decisions. The court held that the reimbursements paid by Marriott Rewards to Dove Mountain constitute gross income for TPT purposes. The court distinguished the case from a previous case, Consumers Market, which Dove Mountain argued was materially indistinguishable. The court found that the nature and operation of the Rewards Program undermined Dove Mountain’s effort to characterize its Points-earning transactions, subsequent redemptions, and Reimbursements as analogous to the “whole transaction” at issue in Consumers Market. The court concluded that Dove Mountain's various characterizations of Reimbursements as “post-tax” reserves, returns of capital, or bank deposits were not supported by the facts or the law. View "DOVE MOUNTAIN v ADOR" on Justia Law

The case involves a dispute between investigative journalist Amy Silverman and the Arizona Department of Economic Security (ADES). Silverman requested access to records maintained by the Adult Protective Services (APS), a program within ADES, for her research on issues affecting individuals with intellectual and developmental disabilities. ADES denied her request, citing a state law that generally shields APS records from public inspection, except for certain exceptions, including one for "bona fide research." Silverman sued ADES, arguing that her journalistic activities qualified as "bona fide research."The Superior Court in Maricopa County ruled in favor of Silverman, finding that her journalistic activities qualified as "bona fide research" and ordered ADES to produce the requested documents after redacting personally identifying information. ADES appealed this decision, and the Court of Appeals affirmed in part, reversed in part, and remanded the case back to the Superior Court. The Court of Appeals concluded that "research" under the exception must be conducted for "educational, administrative, or scientific purposes" and that ADES still has discretion whether to disclose APS records.Both parties were dissatisfied with the Court of Appeals' decision and filed petitions for review with the Supreme Court of the State of Arizona. The Supreme Court concluded that "bona fide research" under the relevant statute occurs when the researcher engages in a good faith and genuine study to acquire more knowledge, discover new facts, or test new ideas concerning reporting or stopping the abuse, exploitation, or neglect of vulnerable adults. The court also held that anyone, including journalists, can qualify under the bona fide research exception. However, the court found that ADES has discretion whether, and on what conditions, to release APS records for bona fide research. The court vacated the Court of Appeals' opinion, affirmed the Superior Court's judgment insofar as it denied ADES's motion to dismiss, but reversed the judgment for Silverman and remanded the case for further proceedings. View "SILVERMAN v ADES" on Justia Law

The case revolves around Manuel Perez-Gutierrez, who was convicted on eight counts of sexual conduct with a minor. The trial court sentenced Perez-Gutierrez to two twenty-year terms of imprisonment for the first two counts and one-year sentences for the remaining six counts, all to be served consecutively. The court had discretion to impose the remaining sentences consecutively or concurrently but failed to state on record the reason for its determination, as required by A.R.S. § 13-711(A). Perez-Gutierrez appealed this omission.The Court of Appeals agreed with Perez-Gutierrez and remanded the case, instructing the trial court to record the reasons for its sentencing determination. The court of appeals' decision was based on the precedent set in cases like State v. Anzivino and State v. Harrison, which established a limited-remand practice for such violations. However, a dissenting judge argued that the violation should be reviewed for fundamental error, not requiring a remand.The Supreme Court of the State of Arizona held that a violation of A.R.S. § 13-711(A) is neither a structural error nor a trial error. Instead, it is akin to an administrative error that a trial court can correct without affecting the disposition. Therefore, the court concluded that a remand for the limited purpose of statutory compliance is appropriate. The court also clarified that the remedy for such a violation does not require resentencing but merely a statement on record explaining the sentencing determination. The court vacated the Court of Appeals' opinion and remanded the case with instructions to suspend the appeal and revest jurisdiction in the trial court to comply with § 13-711(A). View "State v. Perez-Gutierrez" on Justia Law

The case involves the Arizona Republican Party (ARP) and its attorneys, who challenged the manner in which Maricopa County election officials conducted a mandatory hand count of ballots following the 2020 general election. The ARP argued that the hand count should have been based on precincts rather than voting centers, as prescribed by the Election Procedures Manual (EPM). The trial court dismissed the ARP's complaint and awarded attorney fees against the ARP and its attorneys under A.R.S. § 12-349(A)(1) and (F), which provides for such fees if a claim is groundless and not made in good faith. The court of appeals affirmed the trial court's rulings.The Supreme Court of the State of Arizona held that the attorney fees award was improper because the ARP's claim was not groundless, thus there was no need to determine whether the claim was made in the absence of good faith. The court found that the ARP's claim was more than "barely" colorable, as there was a plain-language conflict between § 16-602(B), which requires a precinct hand count, and the 2019 EPM, which permits a voting center hand count. The court also disagreed with the lower courts' rulings that the ARP's claim was groundless due to the unavailability of remedies, the applicability of the election-law time bar on post-election challenges to pre-election procedures, and laches. The court vacated the trial court’s and the court of appeals’ attorney fees awards. View "ARIZONA REPUBLICAN PARTY v RICHER" on Justia Law

Larry Dean Anderson was convicted of conspiracy to commit first-degree murder and sentenced to life in prison without the possibility of release for twenty-five years. Anderson filed a post-conviction relief (PCR) petition, claiming that his attorney erroneously advised him that he was eligible for parole, which led him to reject a plea agreement. The issue was whether this claim for PCR based on ineffective assistance of counsel (IAC) was either precluded or untimely.The Superior Court in Pima County initially dismissed Anderson's request for an evidentiary hearing and denied relief. The court determined that Anderson's IAC claim was not precluded or untimely, but it also determined that Anderson's IAC claim was not colorable. The court of appeals denied relief, determining Anderson's IAC claim was untimely and his delay unexcused. It also held his claim was precluded because he failed to raise it in his previous petitions for PCR.The Supreme Court of the State of Arizona reversed and remanded the case. The court held that Anderson's PCR claim was neither untimely nor precluded and he was entitled to an evidentiary hearing to determine whether he had been offered a plea agreement before his trial. The court found that Anderson's attorney's performance was deficient under Strickland because his error constituted incorrect advice on a significant issue relating to Anderson's potential sentence if convicted. The court also found that Anderson had presented enough evidence for an opportunity to establish the existence of an offered plea agreement at an evidentiary hearing. View "STATE OF ARIZONA v ANDERSON" on Justia Law

The case revolves around Tamira Durand, who was indicted for several fraud-related offenses, including illegally obtaining a credit card in the name of Scott Blum, a prosecutor with the Maricopa County Attorney’s Office (MCAO), the agency responsible for prosecuting Durand. Durand argued that her due process rights would be violated if she was prosecuted by an agency with a conflict of interest, given that Blum, one of the victims in her case, was a prosecutor with MCAO. The trial court granted Durand’s motion, disqualifying MCAO from the case. The State appealed this decision.The trial court's decision to disqualify MCAO was appealed to the Court of Appeals, which accepted jurisdiction but denied relief. The State then petitioned for review by the Supreme Court of the State of Arizona.The Supreme Court of the State of Arizona reversed the trial court's decision, stating that the trial court had erred by not considering the Gomez factors, a set of considerations established in a previous case, Gomez v. Superior Court, when deciding whether to disqualify MCAO. The court held that the trial court should have considered these factors, which include whether the motion is being made for the purposes of harassing the defendant, whether the party bringing the motion will be damaged in some way if the motion is not granted, whether there are any alternative solutions, and whether the possibility of public suspicion will outweigh any benefits that might accrue due to continued representation. The case was remanded back to the trial court for further proceedings, with instructions to apply the Gomez factors and consider Durand’s due process rights. View "State ex rel Mitchell v. Palmer" on Justia Law

The case revolves around a dispute over insurance coverage following a fatal jet ski accident. The owner of A.C. Watercraft Rental, Sayed Mohammed, had sought liability insurance for all his business-owned watercraft through Farm Bureau Property and Casualty Insurance Company, which connected him with Great Divide Insurance Company. However, a Yamaha watercraft involved in a fatal accident was not listed in the policy schedule. Following the accident, Mohammed filed a claim with Great Divide for defense and indemnification, which was denied due to the jet ski not being listed in the policy. Subsequently, the deceased's father, Garbis Satamian, sued A.C. Watercraft, which had to bear its own defense costs.The Superior Court in Maricopa County dismissed Satamian's claims against Great Divide, Farm Bureau, and Risk Placement Services (RPS) on the grounds of statute of limitations. The court found that A.C. Watercraft learned of the negligent procurement of insurance when Great Divide denied coverage in January 2016, and that it “sustained injury in May 2017, when [A.C. Watercraft] incurred attorneys’ fees and costs defending itself.” The court ruled that both the negligent procurement of insurance claim and the promissory estoppel claim were time-barred because each accrued no later than May 2017.Satamian appealed the dismissal, arguing that the discovery rule should have tolled the statute of limitations and that the claims could not have accrued until his underlying action against A.C. Watercraft was final and non-appealable. The Court of Appeals rejected Satamian’s arguments and affirmed the lower court's decision.The Supreme Court of the State of Arizona affirmed the lower courts' decisions, holding that the negligent procurement of insurance and promissory estoppel claims accrued when an insured incurs its own litigation costs for defense against a claim due to an insurer’s negligent failure to obtain insurance coverage. The court found that A.C. Watercraft knew or should have known both the “who” and the “what” of the negligent procurement cause of action by May 2017, and expired by May 2019. The promissory estoppel claim began to accrue by May 2017, and expired by May 2020. Because Satamian filed this lawsuit in June 2021, both claims were time-barred. View "Satamian v. Great Divide Insurance Co." on Justia Law