Arizona Revised Statutes

Ariz. Rev. Stat. § 14-1106 (2026)

Effect of fraud and evasion

✓ current as of May 2026
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If fraud has been perpetrated in connection with any proceeding or in any statement filed under this title or if fraud is used to avoid or circumvent the provisions or purposes of this title, any person injured thereby may obtain appropriate relief against the perpetrator of the fraud or restitution from any person, other than a bona fide purchaser, benefiting from the fraud, whether innocent or not. Any proceeding must be commenced within two years after the discovery of the fraud, but no proceeding may be brought against one not a perpetrator of the fraud later than five years after the time of commission of the fraud. This section has no bearing on remedies relating to fraud practiced on a decedent during his lifetime which affects the succession of his estate.

Notes of Decisions
Cited in 6 cases, 1999–2016 · leading case: Ader v. Est. of Felger, 375 P.3d 97 (Ariz. Ct. App. 2016).
Ader v. Est. of Felger, 375 P.3d 97 (Ariz. Ct. App. 2016). · cites it 4× “Ader additionally asserts that A.R.S. § 14-1106 allows her to bring claims against the Estate after they were discovered.”
Dometri Investments, LLC v. Lind, 177 P.3d 305 (Ariz. Ct. App. 2008). · cites it 4× “Parker either intentionally defrauded Lind and her brother or negligently signed the affidavit, A.R.S. § 14-1106 (2005) provides that “[i]f fraud has been perpetrated in connection with any proceeding or in any statement filed under this title .”
In Re Est. of Parker, 177 P.3d 305 (Ariz. Ct. App. 2008). · cites it 4× “Parker either intentionally defrauded Lind and her brother or negligently signed the affidavit, A.R.S. § 14-1106 (2005) provides that "[i]f fraud has been perpetrated in connection with any proceeding or in any statement filed under this title .”
In Re Est. of Shumway, 3 P.3d 977 (Ariz. Ct. App. 2000). “section 14-1106 (1995) and, in the alternative, from the estate pursuant to A.”
Kimball v. Perkins (Ariz. Ct. App. 2016). · cites it 4× “As relevant here, that statute allows any person injured by “fraud” in connection with probate proceedings to obtain relief from the perpetrator or restitution from the beneficiaries of the fraud, but provides that “no proceeding may be brought against one not a perpetrator of…”
Rodriguez v. Gavette, 3 P.3d 977 (Ariz. Ct. App. 1999). “section 14-1106 (1995) and, in the alternative, from the estate pursuant to A.”
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