LIABILITY - ARIZONA

Sanchez-Ravuelta v. Yavapai County, Town of Dewey-Humboldt State

Supreme Court of Arizona - May 19, 2025 - P.3d - 2025 WL 1427953

Adult and minor passengers, who were injured in multi-vehicle collision allegedly caused by intoxicated driver after he left bar, brought negligence action against state, town, and county, alleging that Department of Liquor Licenses and Control had statutory duty of care to take reasonable measures to prevent bar with liquor license from overserving customers, thereby creating hazardous conditions, and that Department breached such duty.

The Superior Court, Maricopa County, entered judgment that granted state’s and county’s motions to dismiss and town’s motion for judgment on pleadings, dismissing all claims with prejudice, but then, after plaintiffs moved for new trial, entered second judgment, responding to minor plaintiffs’ prior motion to dismiss their claims without prejudice, dismissing minor plaintiffs’ claims against state and county without prejudice and all other claims with prejudice. After plaintiffs appealed both judgments, the Superior Court entered order vacating second judgment, granted in part and denied in part plaintiffs’ motion for new trial, and issued third judgment, dismissing minor plaintiffs’ claims without prejudice and adult plaintiffs’ claims with prejudice. The Superior Court, Julian, J., thereafter entered fourth judgment, clarifying that it was entered as final judgment with no further matters pending. Plaintiffs appealed and town cross-appealed. The Court of Appeals affirmed in part, vacated in part, and remanded. Supreme Court granted further review.

The Supreme Court held that:



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