Arizona Revised Statutes

Ariz. Rev. Stat. § 12-1704 (2026)

Stay of enforcement of judgment

✓ current as of May 2026
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A. If the judgment debtor shows the superior court that an appeal from the foreign judgment is pending or will be taken, or that a stay of execution has been granted, the court shall stay enforcement of the foreign judgment until the appeal is concluded, the time for appeal expires, or the stay of execution expires or is vacated, upon proof that the judgment debtor has furnished the security for the satisfaction of the judgment required by the state in which it was rendered.

B. If the judgment debtor shows the superior court any ground upon which enforcement of a judgment of any superior court of this state would be stayed, the court shall stay enforcement of the foreign judgment for an appropriate period, upon requiring the same security for satisfaction of the judgment which is required in this state.

C. No execution or other process for enforcement of a foreign judgment filed under section 12-1702 shall issue until twenty days after the date the judgment creditor mails the notice of filing of the foreign judgment and files proof of mailing with the clerk as required under section 12-1703.

Notes of Decisions
Cited in 9 cases (2 in the last 5 years), 1977–2026 · leading case: Grynberg v. Shaffer, 165 P.3d 234 (Ariz. Ct. App. 2007).
Grynberg v. Shaffer, 165 P.3d 234 (Ariz. Ct. App. 2007). · cites it 6× “of Commissioners on Uniform State Laws, Revised Uniform Enforcement ofForeign Judgments Act: Proceedings before Comm, of the Whole, at 29 (Aug.”
Jones v. Roach, 575 P.2d 345 (Ariz. Ct. App. 1977). · cites it 2× “§ 12-1702, does not authorize this state to entertain a Rule 60(c) motion to avoid the enforcement of a “foreign judgment” for to do so would not afford finality to the rendering state’s judgment and thus be contrary to the Full Faith and Credit Clause of the United States…”
Phares v. Nutter, 609 P.2d 561 (Ariz. 1980). · cites it 2× “Upon learning of the filing of the Texas judgment in Maricopa County, appellants filed a motion to stay enforcement of the Texas judgment pursuant to A.R.S. § 12-1704. This motion was denied.”
Cristall v. Cristall, 242 P.3d 1060 (Ariz. Ct. App. 2010). · cites it 7× “Robert purportedly filed his objection "pursuant to A.R.S. § 12-1704(C)," the provision allowing for a stay of enforcement of the judgment until twenty days after mailing the notice to the debtor and filing a proof of mailing with the court.”
United Bank of Skyline v. Fales, 395 N.W.2d 131 (Minn. Ct. App. 1986). “The court noted that A.R.S. § 12-1704 does not authorize Arizona to consider a Rule 60(c) motion to avoid enforcement of the foreign judgment because doing so would not accord finality to the rendering state’s judgment and would be contrary to the Full Faith and Credit Clause of…”
Douglas N. Higgins, Inc. v. Songer, 827 P.2d 469 (Ariz. Ct. App. 1991). “§ 12-1704. Stay of enforcement of judgment C.”
Lenk v. Monolithic (Ariz. Ct. App. 2026). · cites it 6× “¶17 Citing A.R.S. § 12-1704 and the California Code of Civil Procedure § 1710.”
Bmo Harris v. Tohatan (Ariz. Ct. App. 2018). · cites it 4× “A.R.S. § 12-1704(C). The Tohatans neither appeared nor objected.”
Cocchia v. Testa (Ariz. Ct. App. 2021). · cites it 2× “]” A.R.S. § 12-1704(A). ¶20 Given the pendency of the appeal in the Connecticut case, the judgment in that proceeding is not yet final under this authority, meaning full faith and credit obligations have not yet attached.”
— Ariz. Rev. Stat. § 12-1704(A) — 1 case
Cocchia v. Testa (Ariz. Ct. App. 2021). “]” A.R.S. § 12-1704(A). ¶20 Given the pendency of the appeal in the Connecticut case, the judgment in that proceeding is not yet final under this authority, meaning full faith and credit obligations have not yet attached.”
— Ariz. Rev. Stat. § 12-1704(C) — 2 cases
Cristall v. Cristall, 242 P.3d 1060 (Ariz. Ct. App. 2010). “Robert purportedly filed his objection "pursuant to A.R.S. § 12-1704(C)," the provision allowing for a stay of enforcement of the judgment until twenty days after mailing the notice to the debtor and filing a proof of mailing with the court.”
Bmo Harris v. Tohatan (Ariz. Ct. App. 2018). “A.R.S. § 12-1704(C). The Tohatans neither appeared nor objected.”
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