Arizona Revised Statutes

Ariz. Rev. Stat. § 12-686 (2026)

Inadmissible evidence

✓ current as of May 2026

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In any product liability action, the following shall not be admissible as direct evidence of a defect:

1. Evidence of advancements or changes in the state of the art subsequent to the time the product was first sold by the defendant.

2. Evidence of any change made in the warnings, design or methods of manufacturing or testing the product or any similar product subsequent to the time the product was first sold by the defendant.

Notes of Decisions

Cited in 11 cases, 1982–2009 · leading case: Readenour v. Marion Power Shovel, 719 P.2d 1058 (Ariz. 1986).

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Readenour v. Marion Power Shovel, 719 P.2d 1058 (Ariz. 1986). · cites it 21× “We have jurisdiction pursuant to Ariz.Const. art. 6, § 5(3) and A.”

Seisinger v. Siebel, 203 P.3d 483 (Ariz. 2009). · cites it 8× “In Readenour , this Court upheld against a separation of powers attack A.R.S. § 12-686(2), which makes inadmissible "as direct evidence of a defect" evidence of changes made by the manufacturer after "the product was first sold by the defendant.”

Baroldy v. Ortho Pharm. Corp., 760 P.2d 574 (Ariz. Ct. App. 1988). · cites it 9× “During jury instructions, the court told the jury, “This evidence has been admitted and should be considered by you only on the issue of whether it contradicts or impeaches Ortho’s claim that its diaphragm was not a cause of Roberta Baroldy’s injuries.”

Hallmark v. Allied Prods. Corp., 646 P.2d 319 (Ariz. Ct. App. 1982). · cites it 4× “Rev. 338 (1981). 5 . The Arizona legislature has addressed this issue in A.”

Dart v. Wiebe Mfg., Inc., 709 P.2d 876 (Ariz. 1985). · cites it 2× “We do not reach any issue posed by A.R.S. § 12-686, which became effective after the date of plaintiffs injury.”

Torres v. Goodyear Tire & Rubber Co., 786 P.2d 939 (Ariz. 1990). · cites it 2× “§ 12-685); and deal with evidentiary issues pertaining to remedial measures (A.R.S. § 12-686). No provision of the statute deals with the question of whether a lessor, a donor, a franchisor, a trademark licensor, or any similar entity should qualify as a manufacturer or seller.”

Grenada Steel Indus., Inc. v. Alabama Oxygen Co., Inc. & Sherwood-Selpac Corp., 695 F.2d 883 (5th Cir. 1983). “§ 27-407 is identical to the federal rule, but adds at the end: “Negligence or culpable conduct, as used in this rule, shall include, but not be limited to, the manufacture and sale of a defective product.”

Readenour v. Marion Power Shovel, 719 P.2d 1070 (Ariz. Ct. App. 1985). · cites it 10× “Appellant contends that admission of the code violated A.R.S. § 12-686, which provides: “In any product liability action, the following shall not be admissible as direct evidence of a defect: 1.”

Volz v. Coleman Co., Inc., 748 P.2d 1187 (Ariz. Ct. App. 1986). · cites it 4× “It charges that admitting those documents into evidence was a violation of A.R.S. § 12-686 which states in pertinent part: *566 In any product liability action, the following shall not be admissible as direct evidence of a defect: 2.”

Hohlenkamp v. Rheem Mfg. Co., 655 P.2d 32 (Ariz. Ct. App. 1982). · cites it 2× “A.R.S. § 12-686(2) which was not in effect on the date of this accident prohibits, in any product liability action, evidence of subsequent changes in order to prove a defect.”

Herndon v. Seven Bar Flying Serv., Inc., 716 F.2d 1322 (10th Cir. 1983). “407(a) (which admit evidence to show dangerous defects in products liability cases) with Ariz.Rev.Stat.Ann. § 12-686(a) and Neb.Rev.”

— Ariz. Rev. Stat. § 12-686(2) — 3 cases

Seisinger v. Siebel, 203 P.3d 483 (Ariz. 2009). “In Readenour , this Court upheld against a separation of powers attack A.R.S. § 12-686(2), which makes inadmissible "as direct evidence of a defect" evidence of changes made by the manufacturer after "the product was first sold by the defendant.”

Readenour v. Marion Power Shovel, 719 P.2d 1058 (Ariz. 1986). “We have jurisdiction pursuant to Ariz.Const. art. 6, § 5(3) and A.”

Hohlenkamp v. Rheem Mfg. Co., 655 P.2d 32 (Ariz. Ct. App. 1982). “A.R.S. § 12-686(2) which was not in effect on the date of this accident prohibits, in any product liability action, evidence of subsequent changes in order to prove a defect.”

— Ariz. Rev. Stat. § 12-686(a) — 2 cases

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