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

Ariz. Rev. Stat. § 12-3201 (2026)

Vexatious litigants; designation; definitions

✓ current as of May 2026
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A. In a noncriminal case, at the request of a party or on the court's own motion, the presiding judge of the superior court or a judge designated by the presiding judge of the superior court may designate a pro se litigant a vexatious litigant.

B. A pro se litigant who is designated a vexatious litigant may not file a new pleading, motion or other document without prior leave of the court.

C. A pro se litigant is a vexatious litigant if the court finds the pro se litigant engaged in vexatious conduct.

D. The requesting party may make an amended request at any time if the court either:

1. Determined that the party is not a vexatious litigant and the requesting party has new information or evidence that is relevant to the determination, even if there is not a pending case in the court.

2. Did not rule on the original request during the pendency of the action, even if there is not a pending case in the court.

E. For the purposes of this section:

1. "Vexatious conduct" includes any of the following:

(a) Repeated filing of court actions solely or primarily for the purpose of harassment.

(b) Unreasonably expanding or delaying court proceedings.

(c) Court actions brought or defended without substantial justification.

(d) Engaging in abuse of discovery or conduct in discovery that has resulted in the imposition of sanctions against the pro se litigant.

(e) A pattern of making unreasonable, repetitive and excessive requests for information.

(f) Repeated filing of documents or requests for relief that have been the subject of previous rulings by the court in the same litigation.

2. "Without substantial justification" has the same meaning prescribed in section 12-349.

 

Notes of Decisions
Cited in 24 cases (16 in the last 5 years), 2015–2025 · leading case: Nancy Bourke v. Roger H. Contreras, 556 P.3d 291 (Ariz. Ct. App. 2024).
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Nancy Bourke v. Roger H. Contreras, 556 P.3d 291 (Ariz. Ct. App. 2024). · cites it 12× “§ 12-3201, which confers an additional source of authority to “designate a pro se litigant a vexatious litigant,” restricting the litigant from filing “a new pleading, motion or other document without prior leave of the court.” Because the superior court cited the statute as the…”
Potter v. Meza (D. Ariz. 2025). · cites it 40× “) In February 19 2024, the Arizona Court of Appeals unanimously affirmed. Potter v. Ariz. House of Reps.”
Potter v. Arizona House (Ariz. Ct. App. 2024). · cites it 27× “¶11 Defendants jointly moved to designate Potter as a vexatious litigant under A.R.S. § 12-3201, alleging the frivolous nature of this case and Potter’s past cases.”
Willis v. Dentists Benefits (Ariz. Ct. App. 2017). · cites it 16× “¶4 Meanwhile, DBIC filed a motion to designate Willis a “vexatious litigant” pursuant to A.R.S. § 12-3201 (2016).3 After initially deferring its ruling on DBIC’s motion to consider additional pleadings, the superior court ultimately granted the motion.”
Potter v. Meza (D. Ariz. 2025). · cites it 8× “at *7 (“The Superior Court Did Not Abuse Its Discretion When 19 It Designated Potter a Vexatious Litigant Under A.R.S. § 12-3201.”). In June 2024, the 20 Arizona Supreme Court denied review.”
Danko v. Dessaules (Ariz. Ct. App. 2023). · cites it 6× “Dessaules also moved under A.R.S. § 12-3201 to declare Danko a vexatious litigant.”
Eden v. Deublein (Ariz. Ct. App. 2018). · cites it 4× “Vexatious conduct includes but is not limited to: (1) the repeated filing of court actions solely or primarily for the purposes of harassment, (2) unreasonably expanding or delaying court proceedings, (3) court actions brought or defended without substantial justification, or…”
Gainey Ranch v. Kraft (Ariz. Ct. App. 2019). · cites it 4× “In the wake of these filing, the HOAs moved to designate Kraft a vexatious litigant under A.R.S. § 12-3201. ¶14 The superior court denied all of Kraft’s arguments either on the merits or as immaterial in the wake of entry of default, struck his answer and motion to dismiss, and…”
Strojnik v. Kashyap (Ariz. Ct. App. 2021). · cites it 4× “Red Lion later successfully moved to have Strojnik designated a vexatious litigant under A.R.S. § 12-3201. The superior court implicitly denied Strojnik’s motion to amend his complaint and filed a final judgment under Rule 54(c).”
McKee v. Lamore (Ariz. Ct. App. 2022). · cites it 4× “at 14, ¶ 17 ; A.R.S. § 12-3201. Because the superior court did not cite A.”
Holmes v. Spector (Ariz. Ct. App. 2023). · cites it 3× “2012); A.R.S. § 12-3201. Here, the superior court made its vexatious litigant determination on January 20, 2022, in cause no.”
Contreras v. Bourke (Ariz. 2025). · cites it 3× “See A.R.S. § 12-3201(A). A vexatious litigant determination is no insignificant matter.”
Show all 24 citing cases →
— Ariz. Rev. Stat. § 12-3201(A) — 5 cases
Nancy Bourke v. Roger H. Contreras, 556 P.3d 291 (Ariz. Ct. App. 2024). “§ 12-3201, which confers an additional source of authority to “designate a pro se litigant a vexatious litigant,” restricting the litigant from filing “a new pleading, motion or other document without prior leave of the court.” Because the superior court cited the statute as the…”
Willis v. Dentists Benefits (Ariz. Ct. App. 2017). “¶4 Meanwhile, DBIC filed a motion to designate Willis a “vexatious litigant” pursuant to A.R.S. § 12-3201 (2016).3 After initially deferring its ruling on DBIC’s motion to consider additional pleadings, the superior court ultimately granted the motion.”
Eden v. Deublein (Ariz. Ct. App. 2018). “Vexatious conduct includes but is not limited to: (1) the repeated filing of court actions solely or primarily for the purposes of harassment, (2) unreasonably expanding or delaying court proceedings, (3) court actions brought or defended without substantial justification, or…”
Pittman v. Gcu (Ariz. Ct. App. 2024).
Contreras v. Bourke (Ariz. 2025). “See A.R.S. § 12-3201(A). A vexatious litigant determination is no insignificant matter.”
— Ariz. Rev. Stat. § 12-3201(B) — 5 cases
Erlick v. Davis (Ariz. Ct. App. 2023).
Danko v. Dessaules (Ariz. Ct. App. 2023). “Dessaules also moved under A.R.S. § 12-3201 to declare Danko a vexatious litigant.”
Potter v. Arizona House (Ariz. Ct. App. 2024). “¶11 Defendants jointly moved to designate Potter as a vexatious litigant under A.R.S. § 12-3201, alleging the frivolous nature of this case and Potter’s past cases.”
Potter v. Meza (D. Ariz. 2025). “) In February 19 2024, the Arizona Court of Appeals unanimously affirmed. Potter v. Ariz. House of Reps.”
Contreras v. Bourke (Ariz. 2025). “See A.R.S. § 12-3201(A). A vexatious litigant determination is no insignificant matter.”
— Ariz. Rev. Stat. § 12-3201(C) — 4 cases
Potter v. Arizona House (Ariz. Ct. App. 2024). “¶11 Defendants jointly moved to designate Potter as a vexatious litigant under A.R.S. § 12-3201, alleging the frivolous nature of this case and Potter’s past cases.”
Lynaugh v. 12th St. (Ariz. Ct. App. 2019).
Danko v. Dessaules (Ariz. Ct. App. 2023). “Dessaules also moved under A.R.S. § 12-3201 to declare Danko a vexatious litigant.”
Parsons v. Harris (Ariz. Ct. App. 2024).
— Ariz. Rev. Stat. § 12-3201(E) — 1 case
Eden v. Deublein (Ariz. Ct. App. 2018). “Vexatious conduct includes but is not limited to: (1) the repeated filing of court actions solely or primarily for the purposes of harassment, (2) unreasonably expanding or delaying court proceedings, (3) court actions brought or defended without substantial justification, or…”
— Ariz. Rev. Stat. § 12-3201(E)(1) — 1 case
Potter v. Arizona House (Ariz. Ct. App. 2024). “¶11 Defendants jointly moved to designate Potter as a vexatious litigant under A.R.S. § 12-3201, alleging the frivolous nature of this case and Potter’s past cases.”
— Ariz. Rev. Stat. § 12-3201(E)(1)(a) — 2 cases
Camboni v. Brnovich (Ariz. Ct. App. 2020).
Potter v. Meza (D. Ariz. 2025). “) In February 19 2024, the Arizona Court of Appeals unanimously affirmed. Potter v. Ariz. House of Reps.”
— Ariz. Rev. Stat. § 12-3201(E)(1)(b) — 2 cases
Willis v. Dentists Benefits (Ariz. Ct. App. 2017). “¶4 Meanwhile, DBIC filed a motion to designate Willis a “vexatious litigant” pursuant to A.R.S. § 12-3201 (2016).3 After initially deferring its ruling on DBIC’s motion to consider additional pleadings, the superior court ultimately granted the motion.”
Gainey Ranch v. Kraft (Ariz. Ct. App. 2019). “In the wake of these filing, the HOAs moved to designate Kraft a vexatious litigant under A.R.S. § 12-3201. ¶14 The superior court denied all of Kraft’s arguments either on the merits or as immaterial in the wake of entry of default, struck his answer and motion to dismiss, and…”
— Ariz. Rev. Stat. § 12-3201(E)(1)(c) — 1 case
Potter v. Arizona House (Ariz. Ct. App. 2024). “¶11 Defendants jointly moved to designate Potter as a vexatious litigant under A.R.S. § 12-3201, alleging the frivolous nature of this case and Potter’s past cases.”
— Ariz. Rev. Stat. § 12-3201(E)(1)(d) — 1 case
Willis v. Dentists Benefits (Ariz. Ct. App. 2017). “¶4 Meanwhile, DBIC filed a motion to designate Willis a “vexatious litigant” pursuant to A.R.S. § 12-3201 (2016).3 After initially deferring its ruling on DBIC’s motion to consider additional pleadings, the superior court ultimately granted the motion.”
— Ariz. Rev. Stat. § 12-3201(E)(1)(f) — 3 cases
Nancy Bourke v. Roger H. Contreras, 556 P.3d 291 (Ariz. Ct. App. 2024). “§ 12-3201, which confers an additional source of authority to “designate a pro se litigant a vexatious litigant,” restricting the litigant from filing “a new pleading, motion or other document without prior leave of the court.” Because the superior court cited the statute as the…”
Willis v. Dentists Benefits (Ariz. Ct. App. 2017). “¶4 Meanwhile, DBIC filed a motion to designate Willis a “vexatious litigant” pursuant to A.R.S. § 12-3201 (2016).3 After initially deferring its ruling on DBIC’s motion to consider additional pleadings, the superior court ultimately granted the motion.”
Potter v. Arizona House (Ariz. Ct. App. 2024). “¶11 Defendants jointly moved to designate Potter as a vexatious litigant under A.R.S. § 12-3201, alleging the frivolous nature of this case and Potter’s past cases.”
— Ariz. Rev. Stat. § 12-3201(E)(2) — 1 case
Potter v. Arizona House (Ariz. Ct. App. 2024). “¶11 Defendants jointly moved to designate Potter as a vexatious litigant under A.R.S. § 12-3201, alleging the frivolous nature of this case and Potter’s past cases.”
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