Arizona Revised Statutes

Ariz. Rev. Stat. § 12-820 (2026)

Definitions

✓ current as of May 2026

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In this article, unless the context otherwise requires:

1. "Employee" includes an officer, director, employee or servant, whether or not compensated or part time, who is authorized to perform any act or service, except that employee does not include an independent contractor. Employee includes noncompensated members of advisory boards appointed as provided by law and leased employees.

2. "Injury" means death, injury to a person, damage to or loss of property or any other injury that a person may suffer that would be actionable if inflicted by a private person.

3. "Leased employee" means a person providing services to a public entity under a lease agreement and is not an independent contractor or temporary employee.

4. "Maintenance" means the establishment or continuation in existence of facilities, highways, roads, streets, bridges or rights-of-way by a public entity and does not mean or refer to ordinary repair or upkeep.

5. "Prisoner" means a person incarcerated while awaiting sentence or while serving a sentence imposed by a court of law.

6. "Public employee" means an employee of a public entity.

7. "Public entity" includes this state and any political subdivision of this state.

8. "State" means this state and any state agency, board, commission or department.

Notes of Decisions

Cited in 81 cases (16 in the last 5 years), 1985–2026 · leading case: Diana Glazer v. State of Arizona, 347 P.3d 1141 (Ariz. 2015).

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Diana Glazer v. State of Arizona, 347 P.3d 1141 (Ariz. 2015). · cites it 16× “) (codified at A.R.S. §§ 12-820 to -826). The Act leaves intact the common-law rule that the government is liable for its tortious conduct unless immunity applies.”

Johnson v. Superior Court, Pima Cnty., 763 P.2d 1382 (Ariz. Ct. App. 1988). · cites it 16× “CLAIMS STATUTES In 1984, the legislature passed a comprehensive act entitled "Actions Against Public Entities or Public Employees," which governs the immunity and liability of public entities and employees.”

Zeigler v. Kirschner, 781 P.2d 54 (Ariz. Ct. App. 1989). · cites it 10× “§ 1983 by a federal qualified executive immunity; (2) whether the director was protected against plaintiffs’ § 1983 claims by either absolute or qualified immunity under A.R.S. § 12-820 et seq.; (3) whether the named plaintiffs’ failure to exhaust their state administrative…”

Gotbaum Ex Rel. Gotbaum v. City of Phoenix, 617 F. Supp. 2d 878 (D. Ariz. 2008). · cites it 6× “See A.R.S. § 12-820, 1984 Laws Ch. 285, § 1 (recognizing that the purpose of A.”

Mccloud v. State, Dept. of Pub. Saf., 170 P.3d 691 (Ariz. Ct. App. 2007). · cites it 4× “The legislature’s alteration of § 12-821, however, does not suggest our interpretation of § 12-820’s definitions in Johnson was error.”

City of Tucson v. Fleischman, 731 P.2d 634 (Ariz. Ct. App. 1986). · cites it 10× “In this special action, we must determine whether A.R.S. §§ 12-820 to -826 apply to cities.”

City of Phoenix v. Fields, 201 P.3d 529 (Ariz. 2009). · cites it 4× “285 (the “1984 Act”) (now codified at A.R.S. §§ 12-820 to - 823). The 1984 Act “declared .”

Villasenor v. Evans, 386 P.3d 1273 (Ariz. Ct. App. 2016). · cites it 12× “¶ 5 In support of his first contention, Vil-lasenor argued that under A.R.S. § 12-820 and various sections of the Flagstaff City Code, Evans was a City “officer” rather than a City “employee.”

Greenwood v. State, 175 P.3d 687 (Ariz. Ct. App. 2008). · cites it 6× “In 1984, the legislature enacted the Actions Against Public Entities or Public Employees Act, codified at A.R.S. §§ 12-820 to -823 (2003), 8 to address the issue of governmental liability for certain negligent acts.”

Clouse Ex Rel. Clouse v. State, 16 P.3d 757 (Ariz. 2001). · cites it 3× “section 12-820); Diaz v. Magma Copper Co.”

Smyser v. City of Peoria, 160 P.3d 1186 (Ariz. Ct. App. 2007). · cites it 4× “3d at 760 ; see generally A.R.S. §§ 12-820 to -826 (2005) (Actions Against Public Entities or Public Employees Act); City of Tucson v.”

Bird v. State Through Corbin, 821 P.2d 287 (Ariz. Ct. App. 1991). · cites it 6× “The legislature accepted this invitation and in 1984 enacted the Actions Against Public Entities or Public Employees Act, codified at A.R.S. §§ 12-820 to 12-823. For a discussion of the legislative history of this act, see City of Tucson v.”

Show all 81 citing cases →

— Ariz. Rev. Stat. § 12-820(1) — 11 cases

Johnson v. Superior Court, Pima Cnty., 763 P.2d 1382 (Ariz. Ct. App. 1988). “CLAIMS STATUTES In 1984, the legislature passed a comprehensive act entitled "Actions Against Public Entities or Public Employees," which governs the immunity and liability of public entities and employees.”

Mccloud v. State, Dept. of Pub. Saf., 170 P.3d 691 (Ariz. Ct. App. 2007). “The legislature’s alteration of § 12-821, however, does not suggest our interpretation of § 12-820’s definitions in Johnson was error.”

Dube v. Desai, 186 P.3d 587 (Ariz. Ct. App. 2008).

Villasenor v. Evans, 386 P.3d 1273 (Ariz. Ct. App. 2016). “¶ 5 In support of his first contention, Vil-lasenor argued that under A.R.S. § 12-820 and various sections of the Flagstaff City Code, Evans was a City “officer” rather than a City “employee.”

Jones-Esposito v. Bishop (Ariz. Ct. App. 2021).

— Ariz. Rev. Stat. § 12-820(2) — 1 case

Burns v. City of Tucson, 432 P.3d 953 (Ariz. Ct. App. 2018).

— Ariz. Rev. Stat. § 12-820(3) — 2 cases

Goss v. City of Globe, 883 P.2d 466 (Ariz. Ct. App. 1994).

Glazer v. State, 321 P.3d 470 (Ariz. Ct. App. 2014).

— Ariz. Rev. Stat. § 12-820(4) — 1 case

Diana Glazer v. State of Arizona, 347 P.3d 1141 (Ariz. 2015). “) (codified at A.R.S. §§ 12-820 to -826). The Act leaves intact the common-law rule that the government is liable for its tortious conduct unless immunity applies.”

— Ariz. Rev. Stat. § 12-820(5) — 3 cases

Nored v. City of Tempe, 614 F. Supp. 2d 991 (D. Ariz. 2008).

McCloud v. State of Arizona Dept. of Pub. Saf. & Kimbro (Ariz. Ct. App. 2007).

— Ariz. Rev. Stat. § 12-820(6) — 14 cases

City of Tucson v. Fleischman, 731 P.2d 634 (Ariz. Ct. App. 1986). “In this special action, we must determine whether A.R.S. §§ 12-820 to -826 apply to cities.”

Smyser v. City of Peoria, 160 P.3d 1186 (Ariz. Ct. App. 2007). “3d at 760 ; see generally A.R.S. §§ 12-820 to -826 (2005) (Actions Against Public Entities or Public Employees Act); City of Tucson v.”

New Pueblo Constructors, Inc. v. State, 696 P.2d 185 (Ariz. 1985).

Flood Control Dist. v. Gaines, 43 P.3d 196 (Ariz. Ct. App. 2002).

— Ariz. Rev. Stat. § 12-820(7) — 10 cases

State Comp. Fund v. Superior Court, 948 P.2d 499 (Ariz. Ct. App. 1997).

Pivotal Colorado II, LLC v. Arizona Pub. Saf. Pers. Ret. Sys., 322 P.3d 186 (Ariz. Ct. App. 2014).

Cochise Cnty. v. Borowiec, 781 P.2d 1379 (Ariz. Ct. App. 1989).

Sanchez v. Maricopa Cnty. (Ariz. Ct. App. 2023).

— Ariz. Rev. Stat. § 12-820(8) — 3 cases

Pivotal Colorado II, LLC v. Arizona Pub. Saf. Pers. Ret. Sys., 322 P.3d 186 (Ariz. Ct. App. 2014).

Pruitt v. State (Ariz. Ct. App. 2025).

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