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

Ariz. Rev. Stat. § 12-2601 (2026)

Definitions

✓ current as of May 2026
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In this article, unless the context otherwise requires:

1. "Claim" means a legal cause of action except for actions relating to health care under sections 12-561 through 12-563 of this title or under title 46, chapter 4 or an affirmative defense to which all of the following apply:

(a) The claim is asserted against a licensed professional in a complaint, answer, cross-claim, counterclaim or third party complaint.

(b) The claim is based on the licensed professional's alleged breach of contract, negligence, misconduct, errors or omissions in rendering professional services.

(c) Expert testimony is necessary to prove the licensed professional's standard of care or liability for the claim.

2. "Expert" means a person who is qualified by knowledge, skill, experience, training or education to express an opinion regarding a licensed professional's standard of care or liability for the claim.

3. "Licensed professional" means a person, corporation, professional corporation, partnership, limited liability company, limited liability partnership or other entity that is licensed by this state to practice a profession or occupation under title 20 or 32 or that is admitted to the state bar.

Notes of Decisions
Cited in 18 cases (5 in the last 5 years), 1994–2026 · leading case: Cornerstone Hosp. of Se. Arizona v. Ernest H. Blackburn, 290 P.3d 460 (Ariz. Ct. App. 2012).
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Cornerstone Hosp. of Se. Arizona v. Ernest H. Blackburn, 290 P.3d 460 (Ariz. Ct. App. 2012). · cites it 5× “Accordingly, in A.R.S. § 12-2601 the legislature defined the term “claim,” acknowledging essentially two species of claims against licensed professionals: claims that the remaining portions of that subsection created, which are not medical-based, and claims “relating to health…”
Warner v. Sw. Desert Images, LLC, 180 P.3d 986 (Ariz. Ct. App. 2008). · cites it 2× “The definition of a “claim” under § 12-2601 does not include one based on vicarious liability.”
Hunter Contracting Co. v. Superior Court, 947 P.2d 892 (Ariz. Ct. App. 1997). · cites it 4× “" See A.R.S. § 12-2601(3) (Supp.1996). A. A Plaintiff Must Hire an Expert Even When None Would Otherwise be Required Hunter argues that § 12-2602 does not infringe upon the fundamental right to pursue a damage action because it merely requires claimants to produce expert…”
Mullin v. Brown, 115 P.3d 139 (Ariz. Ct. App. 2005). · cites it 2× “See A.R.S. § 12-2601(1)(e) (“Expert testimony is necessary to prove the licensed professional’s standard of care or liability for the claim.”
Kaufman v. Jesser, 884 F. Supp. 2d 943 (D. Ariz. 2012). · cites it 4× “Here, the parties mistakenly equate Arizona’s *953 statutory requirements for expert testimony in suits against licensed professionals, A.R.S. §§ 12-2601 to 2605, as State rules on “discovery procedures,” doc.”
Bertleson v. Sacks Tierney, P.A., 60 P.3d 703 (Ariz. Ct. App. 2002). · cites it 2× “…by this state to practice a profession or occupation under title 20 or 32 or that is admitted to the state bar." A.R.S. § 12-2601(3)(2000).”
Valles v. Pima Cnty., 642 F. Supp. 2d 936 (D. Ariz. 2009). · cites it 4× “In addition, Defendants Sack and Long Realty argue that Plaintiffs have failed to comply with A.R.S. §§ 12-2601 et seq., and Defendant Mason contends that Plaintiffs’ negligence claim is barred by the economic loss doctrine.”
Smith v. Myers, 887 P.2d 541 (Ariz. 1994). “These statutes have been renumbered as §§ 12-2601 to -2614 (effective 1993). Our opinion today refers to their original designations.”
AA Mech. v. Superior Court, 948 P.2d 492 (Ariz. Ct. App. 1997). · cites it 2× “) Nowhere in Hunter will the reader find the statutory definition of claim, which appears at § 12-2601(1): "`Claim' means a legal action in tort brought .”
Freeman v. Williams (Ariz. Ct. App. 2021). · cites it 8× “See A.R.S. §§ 12-2601, -2602; see also generally A.”
Kestenbaum v. Ford (Ariz. Ct. App. 2023). · cites it 7× “A.R.S. § 12-2601(1). A licensed professional includes a person licensed by this State to practice “a profession or occupation under title 20 or 32.”
Ramirez (D. Ariz. 2026). · cites it 7× “Rule 8 also controls what information must be 24 included in an answer and it does not require the answering party include a supporting 25 1 Mitchell’s opposition to the motion to strike argues “[a] nonparty designation is not a 26 ‘claim’ within the meaning of A.R.S. §…”
Show all 18 citing cases →
— Ariz. Rev. Stat. § 12-2601(1) — 7 cases
Warner v. Sw. Desert Images, LLC, 180 P.3d 986 (Ariz. Ct. App. 2008). “The definition of a “claim” under § 12-2601 does not include one based on vicarious liability.”
Cornerstone Hosp. of Se. Arizona v. Ernest H. Blackburn, 290 P.3d 460 (Ariz. Ct. App. 2012). “Accordingly, in A.R.S. § 12-2601 the legislature defined the term “claim,” acknowledging essentially two species of claims against licensed professionals: claims that the remaining portions of that subsection created, which are not medical-based, and claims “relating to health…”
AA Mech. v. Superior Court, 948 P.2d 492 (Ariz. Ct. App. 1997). “) Nowhere in Hunter will the reader find the statutory definition of claim, which appears at § 12-2601(1): "`Claim' means a legal action in tort brought .”
Kestenbaum v. Ford (Ariz. Ct. App. 2023). “A.R.S. § 12-2601(1). A licensed professional includes a person licensed by this State to practice “a profession or occupation under title 20 or 32.”
Freeman v. Williams (Ariz. Ct. App. 2021). “See A.R.S. §§ 12-2601, -2602; see also generally A.”
— Ariz. Rev. Stat. § 12-2601(1)(b) — 4 cases
quasar energy Grp. LLC v. WOF SW GGP 1 LLC (D. Ariz. 2019).
Caravetta v. Banner (Ariz. Ct. App. 2017).
Freeman v. Williams (Ariz. Ct. App. 2021). “See A.R.S. §§ 12-2601, -2602; see also generally A.”
Catherine E. Warner v. Sw. Desert Images, LLC (Ariz. Ct. App. 2008).
— Ariz. Rev. Stat. § 12-2601(1)(c) — 1 case
Andrew Mullin v. Brown Chapa Fields Linden (Ariz. Ct. App. 2005).
— Ariz. Rev. Stat. § 12-2601(1)(e) — 1 case
Mullin v. Brown, 115 P.3d 139 (Ariz. Ct. App. 2005). “See A.R.S. § 12-2601(1)(e) (“Expert testimony is necessary to prove the licensed professional’s standard of care or liability for the claim.”
— Ariz. Rev. Stat. § 12-2601(3) — 5 cases
Hunter Contracting Co. v. Superior Court, 947 P.2d 892 (Ariz. Ct. App. 1997). “" See A.R.S. § 12-2601(3) (Supp.1996). A. A Plaintiff Must Hire an Expert Even When None Would Otherwise be Required Hunter argues that § 12-2602 does not infringe upon the fundamental right to pursue a damage action because it merely requires claimants to produce expert…”
Cornerstone Hosp. of Se. Arizona v. Ernest H. Blackburn, 290 P.3d 460 (Ariz. Ct. App. 2012). “Accordingly, in A.R.S. § 12-2601 the legislature defined the term “claim,” acknowledging essentially two species of claims against licensed professionals: claims that the remaining portions of that subsection created, which are not medical-based, and claims “relating to health…”
Kestenbaum v. Ford (Ariz. Ct. App. 2023). “A.R.S. § 12-2601(1). A licensed professional includes a person licensed by this State to practice “a profession or occupation under title 20 or 32.”
Freeman v. Williams (Ariz. Ct. App. 2021). “See A.R.S. §§ 12-2601, -2602; see also generally A.”
quasar energy Grp. LLC v. WOF SW GGP 1 LLC (D. Ariz. 2019).
— Ariz. Rev. Stat. § 12-2601(3)(2000) — 1 case
Bertleson v. Sacks Tierney, P.A., 60 P.3d 703 (Ariz. Ct. App. 2002). “…by this state to practice a profession or occupation under title 20 or 32 or that is admitted to the state bar." A.R.S. § 12-2601(3)(2000).”
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