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

Ariz. Rev. Stat. § 12-864 (2026)

Direct or constructive contempts; punishment

✓ current as of May 2026
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Contempts committed in the presence of the court or so near thereto as to obstruct the administration of justice, and contempts committed by failure to obey a lawful writ, process, order, judgment of the court, and all other contempts not specifically embraced within this article may be punished in conformity to the practice and usage of the common law.

Notes of Decisions
Cited in 34 cases (3 in the last 5 years), 1958–2026 · leading case: Green v. Lisa Frank, Inc., 211 P.3d 16 (Ariz. Ct. App. 2009).
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Green v. Lisa Frank, Inc., 211 P.3d 16 (Ariz. Ct. App. 2009). · cites it 48× “Relying on A.R.S. § 12-864, LFI reasons we lack jurisdiction because the trial court's order sanctioning Green is an order of contempt, based on LFI's request that Green be held in contempt for disobeying the court's orders.”
Ong Hing v. Thurston, 416 P.2d 416 (Ariz. 1966). · cites it 26× “§§ 12-861 through 12-863 instead of A.R.S. § 12-864. A reading, analysis, and comparison of A.”
Owen v. City Court of City of Tucson, 599 P.2d 223 (Ariz. 1979). · cites it 16× “In addition to whatever statutory contempt powers the court may have, see A.R.S. § 12-864 and A.R.S. § 22-423 and Rule 33 of the Rules of Criminal Procedure, 17 A.”
In Re the Appeal in Maricopa Cnty., Juv. Action No. JT-295003, 616 P.2d 84 (Ariz. Ct. App. 1980). · cites it 11× “Second, from their nature the orders here must be regarded simply as contempt orders of the type typically entered under A.R.S. § 12-864, which provides in part as follows: Contempts committed in the presence of the court or so near thereto as to obstruct the administration of…”
Stoddard v. Donahoe, 228 P.3d 144 (Ariz. Ct. App. 2010). · cites it 3× “A.R.S. § 12-864. ¶ 12 Stoddard contends that the superior court, in spite of the finding that he was in “in-direct civil contempt,” actually found him in criminal contempt because the court impliedly found his contumacious conduct “lessens the dignity and authority of the court”…”
Ottaway v. Smith, 113 P.3d 1247 (Ariz. Ct. App. 2005). · cites it 4× “Following the predecessor to A.R.S. § 12-864 and other precedent, the court held that such a charge should “be punished in conformity to the practice and usage of the common law.”
Phoenix Newspapers, Inc. v. Superior Court, 418 P.2d 594 (Ariz. 1966). · cites it 4× “By A.R.S. § 12-864, a court may punish for "* * * contempts committed by failure to obey a lawful writ, process, order [or] judgment of the court * * *.”
Van Baalen v. Superior Court, 508 P.2d 771 (Ariz. Ct. App. 1973). · cites it 6× “§ 12-864, which provides as follows: “Contempts committed in the presence of the court or so near thereto as to obstruct the administration of justice, and contempts committed by failure to obey a lawful writ, process, order, judgment of the court, and all other con-tempts not…”
State v. Deddens, 542 P.2d 1124 (Ariz. 1975). · cites it 4× “Obviously the alleged contempt here is not criminal and therefore ARS § 12-864 applies. Under that statute wilfulness is a necessary element of the contemptuous act alleged.”
Herzog v. Reinhardt, 406 P.2d 738 (Ariz. Ct. App. 1965). · cites it 4× “§ 12-861, but within the scope of A.R.S. § 12-864. A.R.S. § 12-864 provides as follows: “Contempts committed in the presence of the court or so near thereto as to obstruct the administration of justice, and contempts committed by failure to obey a lawful writ, process, order,…”
Flores v. Arizona, 405 F. Supp. 2d 1112 (D. Ariz. 2005). · cites it 2× “Finally, Plaintiffs argue that the State has failed to comply and request the Court to award attorney’s fees and costs for the work related to enforcement of the Court’s orders that they have performed on this case since judgment was issued on January 24, 2000.”
State v. Verdugo, 602 P.2d 472 (Ariz. 1979). · cites it 2× “The punishment was prescribed by A.R.S. § 12-864. Lastly appellant argues that the state cannot prosecute for contempt when immunity could have been given to insulate the witness from the effects of self-incrimination.”
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