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

Ariz. Rev. Stat. § 12-904 (2026)

Commencement of action; transmission of record

✓ current as of May 2026
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A. An action to review a final administrative decision shall be commenced by filing a notice of appeal within thirty-five days from the date when a copy of the decision sought to be reviewed is served upon the party affected. The method of service of the decision shall be as provided by law governing procedure before the administrative agency, or by a rule of the agency made pursuant to law, but if no method is provided a decision shall be deemed to have been served when personally delivered or mailed by certified mail to the party affected at the party's last known residence or place of business. Service is complete on personal service or five days after the date that the final administrative decision is mailed to the party's last known address.  The notice of appeal shall identify the final administrative decision sought to be reviewed and include a statement of the issues presented for review.  The statement of an issue presented for review is deemed to include every subsidiary issue fairly comprised in the statement.

B. Within ten days after filing a notice of appeal pursuant to this article, the party seeking judicial review shall file a notice of the action with the office of administrative hearings or the agency that conducted the hearing, and the office of administrative hearings or the agency that conducted the hearing shall transmit the record to the superior court. The record shall consist of the following:

1. The original agency action from which review is sought.

2. Any motions, memoranda or other documents submitted by the parties to the appeal.

3. Any exhibits admitted as evidence at the administrative hearing.

4. The decision by the administrative law judge and any revisions or modifications to the decision.

5. A copy of the transcript of the administrative hearing, if the party seeking judicial review desires a transcript to be included in the record and provides for preparation of the transcript at the party's own expense. Any other party may have a transcript included in the record by filing a notice with the office of administrative hearings or the agency that conducted the hearing within ten days after receiving notice of the notice of appeal and providing for preparation of the transcript at the party's own expense.

 

Notes of Decisions
Cited in 92 cases (16 in the last 5 years), 1958–2026 · leading case: Johnson v. Arizona Registrar of Contractors, 396 P.3d 645 (Ariz. Ct. App. 2017).
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Johnson v. Arizona Registrar of Contractors, 396 P.3d 645 (Ariz. Ct. App. 2017). · cites it 41× “§ 12-284(A) (2016), which governs fees for civil proceedings, requires an appealing party to pay the clerk of the superior court for filing of a notice of appeal under A.R.S. § 12-904. It would make little sense for an appealing party to pay fees to the superior court if that…”
Thielking v. Kirschner, 859 P.2d 777 (Ariz. Ct. App. 1993). · cites it 17× “Arizona’s Administrative Review Act, A.R.S. sections 12-901 through -914 (1992), establishes a thirty-five day time limit, measured from the date of service of a final administrative decision, for filing a complaint seeking judicial review of an administrative decision.”
M-11 Ltd. P'ship v. Gommard, 330 P.3d 356 (Ariz. Ct. App. 2014). · cites it 9× “It signed and dated its complaint for judicial review on July 18, 2012, and certified that it was mailed that day to the clerk of the Maricopa County Superior Court and to ADOT.”
Grosvenor Holdings, L.C. v. Figueroa, 218 P.3d 1045 (Ariz. Ct. App. 2009). · cites it 2× “See § 12-904(A) (action to review final administrative decision commenced by filing complaint); § 12-904(B) (party seeking review required to file notice of action with office of administrative hearing or agency that conducted hearing within ten days after filing complaint).”
Wassef v. Arizona State Bd. of Dental Examiners ex rel. Hugunin, 393 P.3d 151 (Ariz. Ct. App. 2017). · cites it 3× “08(B) (authorizing the agency head, executive director, commission, or board to “review the [ALJ’s] decision and accept, reject or modify it”).”
Guminski v. The Arizona State Veterinary Med. Examining Bd., 33 P.3d 514 (Ariz. Ct. App. 2001). · cites it 4× “Once the “final administrative decision” has been served on the party, A.R.S. § 12-904 requires that a complaint for judicial review be filed within thirty-five days.”
Rosenberg v. Arizona Bd. of Regents, 578 P.2d 168 (Ariz. 1978). · cites it 6× “A.R.S. § 12-904 provides in part: “An action to review a final administrative decision shall be commenced by filing a complaint within thirty-five days from the date when a copy of the decision sought to be reviewed is served upon the party affected.”
Smith v. Arizona Citizens Clean Elections Comm'n, 132 P.3d 1187 (Ariz. 2006). · cites it 2× “¶29 Smith had the right to seek judicial review of that decision pursuant to the Judicial Review of Administrative Decisions Act (“JRADA”), A.”
Rash v. Town of Mammoth, 315 P.3d 1234 (Ariz. Ct. App. 2013). · cites it 4× “¶ 10 The Town argues that even if the rules do not apply, dismissal was appropriate under A.R.S. § 12-904(A) of the Administrative Review Act (ARA), which it claims applies to this statutory special action.”
Mason v. Arizona, 260 F. Supp. 2d 807 (D. Ariz. 2003). · cites it 4× “A.R.S. § 12-904(A). *822 Second, the Board member decision-makers exist sufficiently independent and free of political influence.”
Arizona Bd. of Regents for & on Behalf of Univ. of Arizona v. State Ex Rel. State, Pub. Saf. Ret. Fund Manager Adm'r, 771 P.2d 880 (Ariz. Ct. App. 1989). · cites it 2× “§ 12-904 provides that “[a]n action to review a final administrative decision shall be commenced by filing a complaint within thirty-five days from the date when a copy of the decision sought to be reviewed is served upon the party affected.” The Fund Manager points out that it…”
United Farm Workers v. Arizona Agric. Emp. Relations Bd., 716 P.2d 439 (Ariz. Ct. App. 1986). · cites it 11× “On December 21, 1982, pursuant to A.R.S. § 12-904, the UFW filed in superior court for judicial review of the above two AERB decisions.”
Show all 92 citing cases →
— Ariz. Rev. Stat. § 12-904(2015) — 1 case
Silver v. Pueblo Del Sol Water Co., 384 P.3d 814 (Ariz. Ct. App. 2016).
— Ariz. Rev. Stat. § 12-904(A) — 34 cases
Johnson v. Arizona Registrar of Contractors, 396 P.3d 645 (Ariz. Ct. App. 2017). “§ 12-284(A) (2016), which governs fees for civil proceedings, requires an appealing party to pay the clerk of the superior court for filing of a notice of appeal under A.R.S. § 12-904. It would make little sense for an appealing party to pay fees to the superior court if that…”
Smith v. Arizona Citizens Clean Elections Comm'n, 132 P.3d 1187 (Ariz. 2006). “¶29 Smith had the right to seek judicial review of that decision pursuant to the Judicial Review of Administrative Decisions Act (“JRADA”), A.”
Rash v. Town of Mammoth, 315 P.3d 1234 (Ariz. Ct. App. 2013). “¶ 10 The Town argues that even if the rules do not apply, dismissal was appropriate under A.R.S. § 12-904(A) of the Administrative Review Act (ARA), which it claims applies to this statutory special action.”
Wassef v. Arizona State Bd. of Dental Examiners ex rel. Hugunin, 393 P.3d 151 (Ariz. Ct. App. 2017). “08(B) (authorizing the agency head, executive director, commission, or board to “review the [ALJ’s] decision and accept, reject or modify it”).”
Mason v. Arizona, 260 F. Supp. 2d 807 (D. Ariz. 2003). “A.R.S. § 12-904(A). *822 Second, the Board member decision-makers exist sufficiently independent and free of political influence.”
— Ariz. Rev. Stat. § 12-904(B) — 10 cases
Grosvenor Holdings, L.C. v. Figueroa, 218 P.3d 1045 (Ariz. Ct. App. 2009). “See § 12-904(A) (action to review final administrative decision commenced by filing complaint); § 12-904(B) (party seeking review required to file notice of action with office of administrative hearing or agency that conducted hearing within ten days after filing complaint).”
Wassef v. Arizona State Bd. of Dental Examiners ex rel. Hugunin, 393 P.3d 151 (Ariz. Ct. App. 2017). “08(B) (authorizing the agency head, executive director, commission, or board to “review the [ALJ’s] decision and accept, reject or modify it”).”
Johnson v. Arizona Registrar of Contractors, 396 P.3d 645 (Ariz. Ct. App. 2017). “§ 12-284(A) (2016), which governs fees for civil proceedings, requires an appealing party to pay the clerk of the superior court for filing of a notice of appeal under A.R.S. § 12-904. It would make little sense for an appealing party to pay fees to the superior court if that…”
Simms v. Simms, 567 P.3d 92 (Ariz. Ct. App. 2025).
Chavez v. Roosevelt Sch. (Ariz. Ct. App. 2019).
— Ariz. Rev. Stat. § 12-904(B)(1) — 1 case
Shea v. Maricopa (Ariz. 2023).
— Ariz. Rev. Stat. § 12-904(a) — 1 case
M-11 Ltd. P'ship v. Gommard, 330 P.3d 356 (Ariz. Ct. App. 2014). “It signed and dated its complaint for judicial review on July 18, 2012, and certified that it was mailed that day to the clerk of the Maricopa County Superior Court and to ADOT.”
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