Arizona Revised Statutes

Ariz. Rev. Stat. § 12-651 (2026)

Uniform single publication act

✓ current as of May 2026
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A. No person shall have more than one cause of action for damages for libel, slander, invasion of privacy or any other tort founded upon a single publication, exhibition or utterance, such as any one edition of a newspaper, book or magazine, any one presentation to an audience, any one broadcast over radio or television or any one exhibition of a motion picture. Recovery in any action shall include all damages for any such tort suffered by the plaintiff in all jurisdictions.

B. A judgment in any jurisdiction for or against the plaintiff upon the substantive merits of any action for damages founded upon a single publication, exhibition or utterance as described in subsection A shall bar any other action for damages by the same plaintiff against the same defendant founded upon the same publication, exhibition or utterance.

C. This section shall be so interpreted as to effectuate its purpose to make uniform the law of those states or jurisdictions which enact it.

D. This section may be cited as the uniform single publication act.

E. This section shall not be retroactive as to causes of action existing on July 1, 1953.

Notes of Decisions
Cited in 10 cases (1 in the last 5 years), 1959–2022 · leading case: Christoff v. Nestle USA, Inc., 213 P.3d 132 (Cal. 2009).
Christoff v. Nestle USA, Inc., 213 P.3d 132 (Cal. 2009). · cites it 2× “" [7] The Court of Appeal further ruled that the two-year statute of limitations set forth in Code of Civil Procedure section 339 applied, that Nestlé knowingly used Christoff's likeness within the meaning of Civil Code section 3344, that the award of more than $15 million for…”
larue/tucker v. Brown, 333 P.3d 767 (Ariz. Ct. App. 2014). · cites it 2× “¶ 20 Arizona has enacted the single publication rule by adopting the Uniform Single Publication Act, which provides: No person shall have more than one cause of action for damages for libel, slander, invasion of privacy or any other tort founded upon a single publication,…”
Fendler v. Phoenix Newspapers, Inc., 636 P.2d 1257 (Ariz. Ct. App. 1981). · cites it 2× “On October 2, 1978, appellees filed a motion to dismiss counts two through seven on grounds that they failed to state a claim and, further, that they were based upon the same publication as count one and were thereby precluded by A.R.S. § 12-651 which limits a plaintiff to “.”
Keeton v. Hustler Magazine, Inc., 549 A.2d 1187 (N.H. 1988). “Ariz. Rev. Stat. Ann. § 12-651 (1982); Cal.”
Strick v. Superior Court, 143 Cal. App. 3d 916 (Cal. Ct. App. 1983). “3], has been adopted in jurisdictions other than New York, namely: Arizona ( Ariz. Rev. Stat. § 12-651 ); California (West’s Ann.”
Bradford v. Am. Media Operations, Inc., 882 F. Supp. 1508 (E.D. Pa. 1995). “The others are Arizona (Ariz.Rev.Stat.Ann. § 12-651 (1982)), California (Cal.”
Ogden v. Ass'n of the United States Army, 177 F. Supp. 498 (D.D.C. 1959). “It should be said in-justice to the plaintiff and in order to make the account complete, that on September 25, 1956, Major General John H. Stokes, Jr., Chief of Military History, wrote a letter to the plaintiff in which he stated that the author of the book was incorrect in…”
Wathan v. Equitable Life Assurance Soc'y of United States, 636 F. Supp. 1530 (C.D. Ill. 1986). “These states are Arizona, A.R.S. § 12-651; California, West’s Ann. Civ.”
Geiger v. Creative Impact Inc. (D. Ariz. 2020). · cites it 3× “” Ariz. Rev. Stat. Ann. § 12-651 (A). Courts have uniformly held that this act applies to internet publications, meaning that “the statute of limitations begins to run when 23 the allegedly defamatory material is first made available to the public by posting it on a website.”
Recovery Hous. Academy LLC v. Candelario (D. Ariz. 2022). · cites it 2× “15 16 A.R.S. § 12-651(A). The Act is meant to prevent multiple suits from republications or sale 17 of the same material.”
— Ariz. Rev. Stat. § 12-651(A) — 3 cases
larue/tucker v. Brown, 333 P.3d 767 (Ariz. Ct. App. 2014). “¶ 20 Arizona has enacted the single publication rule by adopting the Uniform Single Publication Act, which provides: No person shall have more than one cause of action for damages for libel, slander, invasion of privacy or any other tort founded upon a single publication,…”
Recovery Hous. Academy LLC v. Candelario (D. Ariz. 2022). “15 16 A.R.S. § 12-651(A). The Act is meant to prevent multiple suits from republications or sale 17 of the same material.”
Geiger v. Creative Impact Inc. (D. Ariz. 2020). “” Ariz. Rev. Stat. Ann. § 12-651 (A). Courts have uniformly held that this act applies to internet publications, meaning that “the statute of limitations begins to run when 23 the allegedly defamatory material is first made available to the public by posting it on a website.”
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