Justia Injury Law Opinion Summaries

In this insurance dispute, the Supreme Court held that Ariz. Rev. Stat. 20-259.01 mandates that a single policy insuring multiple vehicles provides different underinsured motorist (UIM) coverages for each vehicle rather than a single UIM coverage that applies to multiple vehicles.Plaintiff's mother died in a car crash caused by a neglectful driver. Plaintiff submitted a UIM to CSAA General Insurance Company, her mother's insurer. At the time of the accident, Plaintiff's mother's CSAA policy covered the mother's two vehicles and provided UIM coverage of $50,000 per person. When CSAA paid only $50,000 Plaintiff sought an additional $50,000 under an "intra-policy stacking" theory. After CSAA rejected the claim, Plaintiff sued for declaratory judgment, alleging breach of contract, bad faith, and a class action. CSAA moved to certify two questions. The Supreme Court answered (1) insurers seeking to prevent insureds from stacking UIM coverages under a single, multi-vehicle policy must employ section 20-259.01(H)'s sole prescribed method for limiting stacking; and (2) section 20-259.01(B) does not bar an insured from receiving UIM coverage from the policy in an amount greater than the bodily injury or death liability limits of the policy. View "Franklin v. CSAA General Insurance" on Justia Law

The Supreme Court overruled in substantial part DeGraff v. Smith, 62 Ariz. 261 (1945), which concluded that dismissing a claim against an employee with prejudice serves to exonerate that employee from negligence and thus simultaneously adjudicates a respondent superior claim against the employer, holding that if a tort claim against the employee was dismissed for reasons unrelated to its merits, the respondent superior claim remains viable.Jacob Laurence and his son were injured when a truck owned by Salt River Project Agricultural Improvement & Power District (SRP) and driven by John Gabrielson, SRP's employee, collided with Laurence's vehicle. Laurence brought this action claiming that SRP was vicariously liable for Gabrielson's negligence. The superior court granted Gabrielson's motion for summary judgment as it pertained to Laurence's claim due to untimeliness but denied the motion as it pertained to the minor son's claim. The court then granted SRP's motion for summary judgment on Laurence's respondeat superior claim because the court had granted summary judgment for Gabrielson on that claim. The court ultimately dismissed all claims, and the court of appeals affirmed. The Supreme Court vacated and reversed, holding (1) DeGraff was based on incorrect reasoning; and (2) therefore, the superior court erred in entering summary judgment for SRP. View "Laurence v. Salt River Project Agricultural Improvement & Power District" on Justia Law

The Supreme Court held that certain statements made on air by a radio talk show host about a political figure could not serve as a basis for a defamation action given each statement's content, the overall context, and the protections afforded to core political speech by the First Amendment.Respondent Daniel McCarthy, a "Republican political hopeful," sued James Harris, a radio host on a local station owned by iHeartMedia, Inc. (collectively, Petitioners), alleging that statements made by Harris on his radio show were defamatory. Petitioners filed a motion to dismiss, arguing that the statements were rhetorical hyperbole incapable of being proved false and thus protected by the First Amendment. The trial court denied the motion to dismiss. The Supreme Court reversed, holding that none of the statements at issue were actionable because none of them could be reasonably interpreted as asserting or implying false statements of fact that defamed McCarthy. View "Harris v. Honorable Warner" on Justia Law

The Supreme Court held that Ariz. Rev. Stat. 23-1043.01(B), which limits workers' compensation claims for mental illnesses to those that arise from an "unexpected, unusual or extraordinary stress" situation, does not violate Ariz. Const. art. XVIII, 8 or equal protection guarantees under Ariz. Const. art. II, 13.Plaintiff, an officer with the Tucson Police Department, filed an industrial injury claim arising from an incident in June 2018, claiming that it exacerbated his preexisting post-traumatic stress disorder. An administrative law judge found Plaintiff's claims for mental injuries non-compensable because the June 2018 incident was not an "unexpected, unusual or extraordinary stress" situation under section 23-1043.01(B). The court of appeals affirmed the denial of benefits. The Supreme Court affirmed, holding that section 23-1043.01(B) does not unconstitutionally limit recovery for stress-related workplace injuries. View "Matthews v. Industrial Comm'n" on Justia Law

The Supreme Court held that because Defendant's conduct did not establish a prima facie case for punitive damages in this negligence case, the trial court erred in granting Plaintiffs' motion to obtain Defendant's financial records.Plaintiffs sued Defendant, alleging negligence under a theory of respondent superior. Plaintiffs filed a "Motion on Prima Facie Case for Punitive Damages" seeking to obtain Defendant's financial records, which the superior court granted. At issue before the Supreme Court was whether the superior court erred in granting Plaintiffs' motion without establishing that Defendant's conduct, if proven, was aggravated or outrageous. The Supreme Court reversed, holding (1) to establish a prima facie case for punitive damages necessary to justify the discovery of a defendant's financial information a plaintiff must establish that there is a reasonable likelihood that the punitive damages claim will be submitted to the jury; and (2) a punitive damages claim will be submitted to the jury only where there is proof that the defendant’s conduct was either intended to cause harm, motivated by spite or ill will, or outrageous, in which the defendant consciously pursued a course of conduct knowing that it created a substantial risk of significant injury to others. View "Swift Transportation v. Honorable Carman" on Justia Law

The Supreme Court reversed the judgment of the trial court granting summary judgment in favor of the City of Peoria and dismissing Plaintiff's complaint with prejudice, holding that Plaintiff's statement in her notice of claim that her settlement offer was "valid for thirty (30) days" did not invalidate her notice of claim.At issue was whether a notice of claim is invalid under Ariz. Rev. Stat. 12-821.01 if it provides that the claimant's settlement offer will terminate less than sixty days after the notice is served. More than six months after serving her notice of claim, Plaintiff brought a wrongful death lawsuit against the City. The trial court granted summary judgment for the City on the grounds that the statutory 180-day time period to file a valid notice of claim had passed. The Supreme Court reversed, holding (1) a notice of claim otherwise in compliance with section 12-821.01(A) is not invalid because it purports to set a deadline for settlement prior to the sixty-day period in section 12-821.01(E); and (2) Plaintiff's attempt to shorten the City's statutory sixty-day response deadline in her notice of claim was a legal nullity that did not invalidate her notice of claim. View "James v. City of Peoria" on Justia Law

The Supreme Court held that the National Highway Transportation Safety Administration (the Agency) has not established a clear policy objective concerning automatic emergency breaking (AEB) technology that preempts state tort law claims based on an auto manufacturer's alleged failure to install AEB.Plaintiff sued Chrysler alleging negligence, defective product design, defective product warning, and wrongful death. Chrysler moved to dismiss the lawsuit, asserting that it was preempted given the Agency's objectives regarding the development and deployment of AEB technology. The trial court granted Chrysler's motion. The court of appeals reversed, concluding that the Agency did not intend to preempt tort claims based on the absence of AEB. The Supreme Court reversed the trial court's order, holding (1) the Agency has neither conveyed an authoritative statement establishing manufacturer choice as a significant federal policy objective nor made explicit a view that AEB should not be regulated; and (2) therefore, the Agency has not established a policy objective that actually conflicts with the claims at issue. View "Varela v. FCA US LLC" on Justia Law

The Supreme Court vacated the opinion of the court of appeals reversing the judgment of the trial court denying summary judgment for Defendant and remanded this matter to the trial court to grant summary judgment for Defendant, holding that Plaintiff was not entitled to relief on her defamation claim.This defamation action arose from a political advertisement directed at an opposing candidate, in which the third-party plaintiff was unnamed, the alleged defamation was not expressed but implied, and the asserted implication was not one that a reasonable listener would likely draw. Defendant moved for summary judgment, arguing that the advertisement made truthful claims about matters of public concern and that Defendant did not make the statements with actual malice. The superior court denied the summary judgment motion. The court of appeals reversed. The Supreme Court vacated the court of appeals, holding that the First Amendment does not tolerate a defamation action under the facts presented in this case. View "Rogers v. Honorable Mroz" on Justia Law

The Supreme Court denied relief to Banner University Medical Center Tucson Campus, LLC and other Banner entities (collectively, Banner) which challenged the denial of its motion for summary judgment in this vicarious liability case, holding that the vicarious liability claim against Banner was not precluded.Doctors jointly employed by Banner provided treatment to Plaintiffs' fourteen-month-old son, who died. Plaintiffs brought medical malpractice claims against the doctors, a vicarious liability claim against Banner based on the doctors' conduct, and direct claims of breach of contract and fraud against Banner. The trial court granted summary judgment for the doctors because Plaintiffs failed to serve each of them with a notice of claim. Banner then filed a motion for summary judgment, arguing that the trial court's dismissal of the doctors with prejudice served as an adjudication on the merits precluding any claim of vicarious liability against Banner. The court denied the motion. The Supreme Court affirmed, holding that because there was no final judgment on the merits, Plaintiffs' vicarious liability claim against Banner was not precluded. View "Banner University Medical Center Tucson Campus, LLC v. Honorable Richard Gordon" on Justia Law

The Supreme Court held that a hospital may not directly recover from a third party the costs of uncompensated medical care provided to patients whose need for treatment the third party allegedly caused because the exclusive right for a hospital to recover from a third-party tortfeasor is through the medical lien statutes.Tuscon Medical Center (TMC) brought this action against CVS Health Corporation and other CVS entities (collectively, CVS) alleging that CVS failed to exercise due care in dispensing opioids into Arizona communities. CVS filed a motion to dismiss, arguing that Arizona's medical lien statutes precluded all of TMC's claims against it. The Supreme Court reversed the trial court's ruling denying CVS's motion to dismiss TMC's negligence claims, holding (1) TMC was barred from pursing a negligence claim against CVS to recover indirect damages and was limited to suing the patient or perfecting and collecting on a statutory lien; and (2) CVS did not owe a duty to TMC under the facts alleged. View "CVS Pharmacy, Inc. v. Honorable Bostwick" on Justia Law