Ariz. Rev. Stat. » Title 12
Arizona Revised Statutes

Ariz. Rev. Stat. § 12-1510 (2026)

Fees and expenses of arbitration

✓ current as of May 2026
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Unless otherwise provided in the agreement to arbitrate, the arbitrators' expenses and fees, together with other expenses, not including counsel fees, incurred in the conduct of the arbitration, shall be paid as provided in the award.

Notes of Decisions
Cited in 12 cases, 1994–2015 · leading case: Steer Ex Rel. K & K Cable, Inc. v. Eggleston, 47 P.3d 1161 (Ariz. Ct. App. 2002).
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Steer Ex Rel. K & K Cable, Inc. v. Eggleston, 47 P.3d 1161 (Ariz. Ct. App. 2002). · cites it 14× “The Relevant Statutes ¶ 16 Resolution of this dispute also requires us to consider and interpret A.R.S. §§ 12-1510 (1994) and 29-359. We review questions of statutory interpretation de novo.”
Cal X-Tra v. W.V.S v. Holdings, L.L.C., 276 P.3d 11 (Ariz. Ct. App. 2012). · cites it 7× “§ 29-359 is consistent with the prohibition of A.R.S. § 12-1510 [ (1994) ]. In fact, such an interpretation gives effect to both statutes.”
Wb, the Bldg. Co., LLC. v. El Destino, 257 P.3d 1182 (Ariz. Ct. App. 2011). · cites it 7× “Because we are holding that the arbitration agreement is void and/or voidable, we do not address WB’s arguments that A.R.S. § 12-1510 (2003) precludes an award of attorneys’ fees.”
Canon Sch. Dist. No. 50 v. W.E.S. Constr. Co., 882 P.2d 1274 (Ariz. 1994). · cites it 15× “We start with A.R.S. § 12-1510, a section of the Uniform Act titled “Fees and expenses of arbitration,” which states that “[ujnless otherwise provided in the agreement to arbitrate, the arbitrators’ expenses and fees, together with other expenses, not including counsel fees,…”
City of Cottonwood v. James L. Fann Contracting, Inc., 877 P.2d 284 (Ariz. Ct. App. 1994). · cites it 4× “Arbitrator’s Award Was Final Cottonwood next argues that the claim for attorney’s fees is waived because Fann did not submit the claim to an arbitrator.”
Blitz v. Beth Isaac Adas Israel Congregation, 720 A.2d 912 (Md. 1998). · cites it 3× “Also focusing on that provision, A.R.S. § 12-1510, its version of this State’s § 3-221, 11 the Supreme Court of Arizona acknowledged that “[t]he Uniform Act has taken a different approach, expressly excluding attorneys’ fees in A.”
Canon Sch. Dist. No. 50 v. W.E.S. Constr. Co., 868 P.2d 1014 (Ariz. Ct. App. 1994). · cites it 6× “section 12-1510 precluded an award of attorney’s fees incurred in the arbitration proceeding; (3) AR.”
Warfield v. Gardner, 346 F. Supp. 2d 1033 (D. Ariz. 2004). · cites it 2× “Instead, the Court found that the state’s Director of Insurance, “appoints the receiver pursuant to a legislative scheme designed to protect the public from the dangers of a non-complying insurance company.” Id. at 66. It noted that in bringing the delinquency proceedings,…”
Blitz v. Beth Isaac Adas Israel Congregation, 694 A.2d 107 (Md. Ct. Spec. App. 1997). “The Uniform Act has taken a different approach, expressly excluding attorney’s fees in A.R.S. § 12-1510 [the section governing expenses of the arbitration itself], but not excluding fees in the confirmation section.”
Canon Sch. Dist. v. Wes Constr. Co. IV, 882 P.2d 1274 (Ariz. 1994). · cites it 15× “We start with A.R.S. § 12-1510, a section of the Uniform Act titled "Fees and expenses of arbitration," which states that "[u]nless otherwise provided in the agreement to arbitrate, the arbitrators' expenses and fees, together with other expenses, not including counsel fees,…”
Stratton v. Weaver (Ariz. Ct. App. 2014). · cites it 7× “A.R.S. § 12-1510 Did Not Prohibit the Award ¶22 Weaver argues that because the partnership agreement did not provide for an award of attorneys’ fees incurred in an arbitration proceeding, A.”
Frazer v. Frazzano (Ariz. Ct. App. 2015). · cites it 2× “” A.R.S. § 12-1510 (emphasis added). Frazzano cites to no provision in the arbitration agreement precluding such an allocation of arbitration fees and costs, and the court has found none.”
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