14-5110. Claim deadline for compensation; definitions
A. In a guardianship, conservatorship or protective proceeding, unless a later claim deadline is established in advance by the court, a claim for compensation by attorneys or guardians ad litem who intend to be paid by the ward or protected person's estate is waived if not submitted to the fiduciary in writing within four months after either rendering the service, incurring the cost, initial appointment of the fiduciary or the effective date of this section, whichever is later. A claim is deemed submitted on delivery, mailing or electronic transmission to the fiduciary. A subsequent appointment of a substitute fiduciary does not renew the claim period.
B. This section does not apply to an attorney seeking compensation based on a contingency fee agreement.
C. For the purposes of this section:
1. "Compensation" includes fees, costs and reimbursable expenses.
2. "Estate" includes any estate established pursuant to this title except a trust unless the trust is supervised by the court and the ward or protected person is a beneficiary.
Notes of Decisions
In the Matter of William John Chalmers (Ariz. 2025).
· cites it 13× “Put simply, “had the legislature intended to impose such an overarching, automatic procedural bar, it would have done so explicitly—as it plainly did in § 14-5110—not by implication.” Id. at 277 ¶ 30.”
Chalmers v. East Valley (Ariz. Ct. App. 2023).
· cites it 9× “¶29 The absence of language in § 14-5109 creating an absolute bar to payment of requested fees if a preliminary notice is not provided is particularly significant when the statute is read in conjunction with A.R.S. § 14-5110. That provision establishes a time limit for seeking…”
Esparza v. Warner (Ariz. Ct. App. 2025).
· cites it 4× “33(e) (“An attorney, a guardian ad litem, or a statutory representative waives compensation from the estate of a ward or protected person if a request is not timely submitted under A.R.S. § 14-5110.”); Ariz. R. Civ. P. 60(b)(5) (“[T]he court may relieve a party or its legal…”
Ariz. Rev. Stat. § 14-5110(A): 2 cases
In the Matter of William John Chalmers (Ariz. 2025).
“Put simply, “had the legislature intended to impose such an overarching, automatic procedural bar, it would have done so explicitly—as it plainly did in § 14-5110—not by implication.” Id. at 277 ¶ 30.”
Chalmers v. East Valley (Ariz. Ct. App. 2023).
“¶29 The absence of language in § 14-5109 creating an absolute bar to payment of requested fees if a preliminary notice is not provided is particularly significant when the statute is read in conjunction with A.R.S. § 14-5110. That provision establishes a time limit for seeking…”
Ariz. Rev. Stat. § 14-5110(a): 1 case
Esparza v. Warner (Ariz. Ct. App. 2025).
“33(e) (“An attorney, a guardian ad litem, or a statutory representative waives compensation from the estate of a ward or protected person if a request is not timely submitted under A.R.S. § 14-5110.”); Ariz. R. Civ. P. 60(b)(5) (“[T]he court may relieve a party or its legal…”
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