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

Ariz. Rev. Stat. § 12-2234 (2026)

Attorney and client

✓ current as of May 2026
Find cases: SyfertCases citing this section AZ-LEGazleg.gov (official) JustiaTitle on Justia CornellLII Search CasesGoogle Scholar

A. In a civil action an attorney shall not, without the consent of his client, be examined as to any communication made by the client to him, or his advice given thereon in the course of professional employment. An attorney's paralegal, assistant, secretary, stenographer or clerk shall not, without the consent of his employer, be examined concerning any fact the knowledge of which was acquired in such capacity.

B. For purposes of subsection A, any communication is privileged between an attorney for a corporation, governmental entity, partnership, business, association or other similar entity or an employer and any employee, agent or member of the entity or employer regarding acts or omissions of or information obtained from the employee, agent or member if the communication is either:

1. For the purpose of providing legal advice to the entity or employer or to the employee, agent or member.

2. For the purpose of obtaining information in order to provide legal advice to the entity or employer or to the employee, agent or member.

C. The privilege defined in this section shall not be construed to allow the employee to be relieved of a duty to disclose the facts solely because they have been communicated to an attorney.

Notes of Decisions
Cited in 71 cases (10 in the last 5 years), 1958–2026 · leading case: The Salvation Army Kelley v. Bennett, 273 P.3d 656 (Ariz. Ct. App. 2012).
Sort: Relevance Newest Treatment
The Salvation Army Kelley v. Bennett, 273 P.3d 656 (Ariz. Ct. App. 2012). · cites it 24× “For the reasons that follow, we conclude those interviews fall within the provisions of AR.S. § 12-2234 and therefore are protected by the attorney-client privilege.”
Roman Catholic Diocese v. Superior Court, 62 P.3d 970 (Ariz. Ct. App. 2003). · cites it 10× “It asks us to interpret the criminal privilege statute to incorporate the 1994 amendment to A.R.S. § 12-2234 (Supp. 2002) (amended by Ariz.”
Kline v. Kline, 212 P.3d 902 (Ariz. Ct. App. 2009). · cites it 4× “A.R.S. § 12-2234 (2003). The statute provides that “[i]n a civil action an attorney shall not, without the consent of his client, be examined as to any communication made by the client to him, or his advice given thereon in the course of professional employment.”
Hunt v. Maricopa Cnty. Employees Merit Sys. Comm'n, 619 P.2d 1036 (Ariz. 1980). · cites it 8× “It must also be noted that this grant of permission for lay representation does not affect the provisions of A.R.S. § 12-2234 which makes communications between attorney and client privileged.”
State v. Melendez, 834 P.2d 154 (Ariz. 1992). · cites it 8× “2d 1036, 1041 (1980), in which, after holding that lay representation of employees was permitted in administrative hearings dealing with personnel matters, we noted that "this grant of permission for lay representation does not affect the provisions of A.R.S. § 12-2234 which…”
Samaritan Found. v. Superior Court, 844 P.2d 593 (Ariz. Ct. App. 1993). · cites it 12× “However, Arizona's attorney-client privilege statute, A.R.S. § 12-2234, does not exclude the corporate client.”
Twin City Fire Ins. v. Burke, 63 P.3d 282 (Ariz. 2003). · cites it 2× “See A.R.S. § 12-2234. Given the record and the judge’s reference to Lee , the judge apparently believed that, in light of our holding in Lee , Twin City had waived the privilege.”
Ulibarri v. Superior Ct. Cty. of Coconino, 909 P.2d 449 (Ariz. Ct. App. 1995). · cites it 6× “See A.R.S. § 12-2234 (attorney-client privilege); § 12-2232 (marital privilege); § 12-2233 (clergy-penitent privilege); § 12-2235 (physician-patient privilege).”
Sell v. Country Life Ins. Co., 189 F. Supp. 3d 925 (D. Ariz. 2016). · cites it 6× “§ 12-2234(B), attorney-client communications are protected from disclosure if the communication is either (1) for the purpose of providing legal advice to the entity or employer or to the employee, agent or member, or (2) for the purpose of obtaining information in order to.”
United California Bank v. Prudential Ins. Co. of Am., 681 P.2d 390 (Ariz. Ct. App. 1983). · cites it 2× “A.R.S. § 12-2234; 1 M. Udall & J. Livermore, Arizona Practice: Law of Evidence § 74 (2d ed.”
Lund v. Donahoe, 261 P.3d 456 (Ariz. Ct. App. 2011). · cites it 4× “See also A.R.S. § 12-2234 (protecting “any communication” made by the client to the attorney or the attorney’s advice given to the client).”
Arizona Indep. Redistricting Comm'n v. Fields, 75 P.3d 1088 (Ariz. Ct. App. 2003). · cites it 2× “Because the attorney-client privilege only applies to confidential communications made for the purpose of obtaining or providing legal assistance for the client, A.R.S. § 12-2234(B) (2003), it follows that the common interest doctrine protects only those communications made to…”
Show all 71 citing cases →
— Ariz. Rev. Stat. § 12-2234(0) — 1 case
Phoenix Child.'s Hosp., Inc. v. Grant, 265 P.3d 417 (Ariz. Ct. App. 2011).
— Ariz. Rev. Stat. § 12-2234(A) — 10 cases
In Re: Mh2019-004895, 468 P.3d 1244 (Ariz. Ct. App. 2020).
Burch v. Hon. myers/hon. bassett/lund, 351 P.3d 376 (Ariz. Ct. App. 2015).
Accomazzo v. Kemp, 319 P.3d 231 (Ariz. Ct. App. 2014).
Robert W. Baird & Co. v. Whitten, 418 P.3d 894 (Ariz. Ct. App. 2017).
Hammerman v. N. Trust Co., 329 P.3d 1055 (Ariz. Ct. App. 2014).
— Ariz. Rev. Stat. § 12-2234(B) — 9 cases
Arizona Indep. Redistricting Comm'n v. Fields, 75 P.3d 1088 (Ariz. Ct. App. 2003). “Because the attorney-client privilege only applies to confidential communications made for the purpose of obtaining or providing legal assistance for the client, A.R.S. § 12-2234(B) (2003), it follows that the common interest doctrine protects only those communications made to…”
Bickler v. Senior Lifestyle Corp., 266 F.R.D. 379 (D. Ariz. 2010).
Sell v. Country Life Ins. Co., 189 F. Supp. 3d 925 (D. Ariz. 2016). “§ 12-2234(B), attorney-client communications are protected from disclosure if the communication is either (1) for the purpose of providing legal advice to the entity or employer or to the employee, agent or member, or (2) for the purpose of obtaining information in order to.”
The Salvation Army Kelley v. Bennett, 273 P.3d 656 (Ariz. Ct. App. 2012). “For the reasons that follow, we conclude those interviews fall within the provisions of AR.S. § 12-2234 and therefore are protected by the attorney-client privilege.”
Hiatt v. Sun City Festival Cmty. Ass'n Inc. (D. Ariz. 2024).
— Ariz. Rev. Stat. § 12-2234(B)(2) — 1 case
Nyerges v. Hillstone Restaurant Grp. Inc. (D. Ariz. 2020).
— Ariz. Rev. Stat. § 12-2234(C) — 5 cases
Sell v. Country Life Ins. Co., 189 F. Supp. 3d 925 (D. Ariz. 2016). “§ 12-2234(B), attorney-client communications are protected from disclosure if the communication is either (1) for the purpose of providing legal advice to the entity or employer or to the employee, agent or member, or (2) for the purpose of obtaining information in order to.”
Nyerges v. Hillstone Restaurant Grp. Inc. (D. Ariz. 2020).
Phoenix Child.'s Hosp., Inc. v. Grant, 265 P.3d 417 (Ariz. Ct. App. 2011).
Flowers-Carter v. Braun Corp. (D. Ariz. 2020).
Nyerges v. Hillstone Restaurant Grp. Inc. (D. Ariz. 2020).
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.