Ariz. Rev. Stat. » Title 14
Arizona Revised Statutes

Ariz. Rev. Stat. § 14-10205 (2026)

Alternative dispute resolution

✓ current as of May 2026
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14-10205. Alternative dispute resolution

A trust instrument may provide mandatory, exclusive and reasonable procedures to resolve issues between the trustee and interested persons or among interested persons with regard to the administration or distribution of the trust.

 

Notes of Decisions
Cited in 10 cases (2 in the last 5 years), 2011–2026 · leading case: Dueñas v. Life Care Centers of Am., Inc., 336 P.3d 763 (Ariz. Ct. App. 2014).
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Dueñas v. Life Care Centers of Am., Inc., 336 P.3d 763 (Ariz. Ct. App. 2014). · cites it 2× “Gov’t of Turkmenistan, 345 F.3d 347 (5th Cir.2003). On this record, however, no circumstances appear to suggest that any exception to the general rule applies.”
Hal Rachal, Jr. v. John W. Reitz, 403 S.W.3d 840 (Tex. 2013). “These courts generally concluded that a trust’s arbitration provision is not enforceable because a trust is not a contract between the grant- or, trustee, and beneficiary and thus does not bind those who do no sign the instrument to arbitrate future trust disputes. This…”
Rachal v. Reitz, 347 S.W.3d 305 (Tex. App. 2011). · cites it 3× “) (current version at Ariz.Rev.Stat. Ann. § 14-10205 OVest, Westlaw through 1st & 2d Special Sess.”
Gibbons v. Anderson, 575 S.W.3d 144 (Ark. Ct. App. 2019). “Ariz. Rev. Stat. Ann. § 14-10205 . Like the Florida statute, the Arizona statute does not enforce arbitration provisions that require arbitration of the validity of a trust document.”
May v. May (Ariz. Ct. App. 2026). · cites it 31× “” A.R.S. § 14-10205. The trust documents in this case include such an ADR provision.”
Phoenix-Tucson v. Deetz (Ariz. Ct. App. 2017). · cites it 2× “) (current version at A.R.S. § 14-10205 (2012)). Such an agreement is valid and enforceable “except on a ground that exists at law or in equity for the revocation of a contract.”
Turley v. Beus (Ariz. Ct. App. 2017). · cites it 2× “3d at 362 ), superseded by A.R.S. § 14-10205; see also Austin, 237 Ariz.”
Phoenix-Tucson v. Deetz (Ariz. Ct. App. 2017). · cites it 2× “) (current version at A.R.S. § 14-10205 (2012)). Such an agreement is valid and enforceable “except on a ground that exists at law or in equity for the revocation of a contract.”
Trs. of IBEW & Arizona Chapter NECA Health & Welfare Trust Fund v. CIGNA Health & Life Ins. Co. (D. Ariz. 2021). · cites it 2× “2004), superseded on other 3 grounds by A.R.S. § 14-10205; Turley v. Beus, No. 1 CA-CV 15-0107, 2017 WL 410976 , 4 at *6 (Ariz.”
Bird v. Djo LLC (D. Ariz. 2020). “23 2004), superseded on other grounds by Arizona Revised Statute § 14-10205. 24 Though Plaintiff was able to earn a sales commission after signing the addenda, the 25 Court finds that such a benefit was indirect.”
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