Ariz. Rev. Stat. » Title 21
Arizona Revised Statutes

Ariz. Rev. Stat. § 21-211 (2026)

Disqualification

✓ current as of May 2026
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The following persons shall be disqualified to serve as jurors in any particular action:

1. Witnesses in the action.

2. Persons interested directly or indirectly in the matter under investigation.

3. Persons related by consanguinity or affinity within the fourth degree to either of the parties to the action or proceedings.

4. Persons biased or prejudiced in favor of or against either of the parties.

Notes of Decisions
Cited in 36 cases (17 in the last 5 years), 1965–2026 · leading case: State v. Eddington.
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State v. Eddington (Ariz. Ct. App. 2010). · cites it 44× “¶ 42 Relying upon A.R.S. § 21-211, my colleagues conclude today that the trial court erred by failing to disqualify the deputy because he had an interest in the case.”
State of Arizona v. Douglas Lee Eddington (Ariz. 2011). · cites it 18× “Section 21-211(4) similarly bars “[pjersons biased or prejudiced in favor of or against either of the parties.”
State v. Thornton (Ariz. 1996). · cites it 8× “Thornton’s challenge for cause was based on A.R.S. § 21-211(1), which states that a “[wjitness in the action” “shall be disqualified to serve as juror[].”
State of Arizona v. James Clayton Johnson (Ariz. 2019). · cites it 2× “3d at 1058, while § 21-211(2), (3), and (4) bar jurors who are interested in the matter or "biased or prejudiced in favor of or against either of the parties.”
State of Arizona v. Jose Alejandro Acuna Valenzuela (Ariz. 2018). · cites it 4× “Juror rehabilitation and strikes for cause ¶ 20 Acuna claims that prospective Jurors 23, 100, 122, and 140 (seated Jurors 4, 9, 10, and 11, respectively) expressed a predisposition for the death penalty and inability to consider mitigation.”
State of Arizona v. Joel Randu Escalante-Orozco (Ariz. 2017). “Ross, and Escalante-Orozco did not question her about it. He speculates that it was “likely” that Dr.”
Zuluaga ex rel. Zuluaga v. Bashas', Inc. (Ariz. Ct. App. 2017). · cites it 2× “” Id; see A.R.S. § 21-211 (listing grounds for challenge for cause); Ariz.”
State of Arizona v. Jose Luis Jimenez (Ariz. Ct. App. 2023). · cites it 3× “II, § 24; A.R.S. § 21-211; Ariz. R. Crim. P. 18.4(b); see also Morgan v.”
Franzi v. Superior Court of Arizona (Ariz. 1984). · cites it 2× “2(a), (persons who are witnesses in an action may not serve as grand jurors) and A.R.S. § 21-211(1) (persons who are witnesses in an action may not serve as jurors).”
State of Arizona v. Shawn Patrick Lynch (Ariz. 2015). · cites it 2× “4(b); see also A.R.S. § 21-211. We examine three factors when determining if a juror may continue to serve after that juror’s objectivity is challenged: (1) the nature of the relationship between the witness and the juror; (2) whether the juror will properly assess the…”
State of Arizona v. Dimitri Polanco Romero (Ariz. Ct. App. 2024). · cites it 4× “Failure to Strike Juror for Cause ¶9 For the first time on appeal, Romero argues the trial court erred by failing to remove a juror “who was not qualified to serve under A.R.S. § 21-211 and State v. Eddington, 228 Ariz.”
State v. Narten (Ariz. 1965). “A prospective juror may be disqualified if he is biased for or against defendant § 21-211, subsec. 4, if he holds an unqualified opinion, Rule 218, or if his opinion will prevent him from acting with entire impartiality Rule 219, subsec.”
Show all 36 citing cases →
— Ariz. Rev. Stat. § 21-211(1) — 5 cases
State v. Thornton (Ariz. 1996). “Thornton’s challenge for cause was based on A.R.S. § 21-211(1), which states that a “[wjitness in the action” “shall be disqualified to serve as juror[].”
Franzi v. Superior Court of Arizona (Ariz. 1984). “2(a), (persons who are witnesses in an action may not serve as grand jurors) and A.R.S. § 21-211(1) (persons who are witnesses in an action may not serve as jurors).”
Franzi v. Superior Court (Ariz. 1984).
State v. Rodriguez (Ariz. Ct. App. 2024).
State of Arizona v. Max G. Moreno (Ariz. Ct. App. 2026).
— Ariz. Rev. Stat. § 21-211(2) — 14 cases
State v. Eddington (Ariz. Ct. App. 2010). “¶ 42 Relying upon A.R.S. § 21-211, my colleagues conclude today that the trial court erred by failing to disqualify the deputy because he had an interest in the case.”
State of Arizona v. Douglas Lee Eddington (Ariz. 2011). “Section 21-211(4) similarly bars “[pjersons biased or prejudiced in favor of or against either of the parties.”
State of Arizona v. James Clayton Johnson (Ariz. 2019). “3d at 1058, while § 21-211(2), (3), and (4) bar jurors who are interested in the matter or "biased or prejudiced in favor of or against either of the parties.”
State of Arizona v. Jose Alejandro Acuna Valenzuela (Ariz. 2018). “Juror rehabilitation and strikes for cause ¶ 20 Acuna claims that prospective Jurors 23, 100, 122, and 140 (seated Jurors 4, 9, 10, and 11, respectively) expressed a predisposition for the death penalty and inability to consider mitigation.”
State of Arizona v. Dimitri Polanco Romero (Ariz. Ct. App. 2024). “Failure to Strike Juror for Cause ¶9 For the first time on appeal, Romero argues the trial court erred by failing to remove a juror “who was not qualified to serve under A.R.S. § 21-211 and State v. Eddington, 228 Ariz.”
— Ariz. Rev. Stat. § 21-211(3) — 5 cases
State v. Eddington (Ariz. Ct. App. 2010). “¶ 42 Relying upon A.R.S. § 21-211, my colleagues conclude today that the trial court erred by failing to disqualify the deputy because he had an interest in the case.”
Allen v. Sanders (Ariz. Ct. App. 2015).
State v. Cockhearn (Ariz. Ct. App. 2024).
State v. Eddington (Ariz. Ct. App. 2010).
State of Arizona v. Douglas Lee Eddington (Ariz. Ct. App. 2010).
— Ariz. Rev. Stat. § 21-211(4) — 14 cases
State of Arizona v. Douglas Lee Eddington (Ariz. 2011). “Section 21-211(4) similarly bars “[pjersons biased or prejudiced in favor of or against either of the parties.”
State of Arizona v. Jose Luis Jimenez (Ariz. Ct. App. 2023). “II, § 24; A.R.S. § 21-211; Ariz. R. Crim. P. 18.4(b); see also Morgan v.”
State of Arizona v. Larry James Fournier (Ariz. Ct. App. 2023).
State of Arizona v. Max G. Moreno (Ariz. Ct. App. 2026).
Jamie Clem v. Pinal Cnty., Pinal Cnty. Sheriff Mark Lamb (Ariz. Ct. App. 2025).
— Ariz. Rev. Stat. § 21-211(l) — 1 case
State of Arizona v. Douglas Lee Eddington (Ariz. 2011). “Section 21-211(4) similarly bars “[pjersons biased or prejudiced in favor of or against either of the parties.”
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