Arizona Revised Statutes

Ariz. Rev. Stat. § 22-406 (2026)

Civil action to recover penalty; procedure

✓ current as of May 2026

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The city or town may maintain a civil action in the municipal court for the recovery of a penalty or forfeiture provided for the violation of an ordinance. The action shall be brought and conducted as civil actions in justice courts.

Notes of Decisions

Cited in 4 cases, 2006–2018 · leading case: William Roubos v. Hon. Leslie miller/tucson, 153 P.3d 1045 (Ariz. 2007).

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William Roubos v. Hon. Leslie miller/tucson, 153 P.3d 1045 (Ariz. 2007). · cites it 9× “The legislature has allowed civil infraction proceedings to be conducted as civil actions: The city or town may maintain a civil action in the municipal court for the recovery of a penalty or forfeiture provided for the violation of an ordinance.”

Roubos v. Miller, 138 P.3d 735 (Ariz. Ct. App. 2006). · cites it 10× “Current A.R.S. § 22-406, which uses nearly identical language in its relevant parts to precursor provisions dating to at least 1909, states: “The city or town may maintain a civil action in the municipal court for the recovery of a penalty or forfeiture provided for the…”

Foor v. Smith, 416 P.3d 858 (Ariz. Ct. App. 2018). · cites it 3× “See A.R.S. § 22-406. Thus, defendants in a forfeiture action before the superior court, justice court, and most municipal courts may seek almost any potentially relevant information about the petitioner's case, including exculpatory and impeachment information.”

Roubos v. City of Tucson (Ariz. Ct. App. 2006). · cites it 10× “Current A.R.S. § 22-406, which uses nearly identical language in its relevant parts to precursor provisions dating to at least 1909, states: “The city or town may maintain a civil action in the municipal court for the recovery of a penalty or forfeiture provided for 5 the…”

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