Ariz. Rev. Stat. » Title 23
Arizona Revised Statutes

Ariz. Rev. Stat. § 23-352 (2026)

Withholding of wages

✓ current as of May 2026
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No employer may withhold or divert any portion of an employee's wages unless one of the following applies:

1. The employer is required or empowered to do so by state or federal law.

2. The employer has prior written authorization from the employee.  An employer shall not withhold wages under a written authorization from the employee past the date specified by the employee in a written revocation of the authorization, unless the withholding is to resolve a debt or obligation to the employer or a court orders otherwise.

3. There is a reasonable good faith dispute as to the amount of wages due, including the amount of any counterclaim or any claim of debt, reimbursement, recoupment or set-off asserted by the employer against the employee.

 

Notes of Decisions
Cited in 34 cases (8 in the last 5 years), 1982–2026 · leading case: Sanborn v. Brooker & Wake Prop. Mgmt., Inc., 874 P.2d 982 (Ariz. Ct. App. 1994).
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Sanborn v. Brooker & Wake Prop. Mgmt., Inc., 874 P.2d 982 (Ariz. Ct. App. 1994). · cites it 15× “” A.R.S. § 23-352. In our opinion this is the proper interpretation of this exception and the only one that is consistent with prior case law, legislative intent, and the language of the statute itself.”
United Food & Com. Workers Local 99 v. Bennett, 934 F. Supp. 2d 1167 (D. Ariz. 2013). · cites it 14× “Finally, SB 1363 amends A.R.S. § 23-352, dealing with the withholding of wages, *1192 to forbid an employer from withholding any wages “under a written authorization from the employee past the date specified by the employee in a written revocation of the authorization.”
Am. Fed'n of State, Cnty. & Mun. Employees v. City of Phoenix, 142 P.3d 234 (Ariz. Ct. App. 2006). · cites it 10× “6 The City also argued that including any language in a current or future Memorandum of Understanding (“MOU”) 7 requiring non-union employees to pay their “fair share” of the unions’ expenses would violate A.R.S. § 23-352 8 and subject the City to liability for the allegedly…”
Miller v. Hehlen, 104 P.3d 193 (Ariz. Ct. App. 2005). · cites it 2× “Although Hehlen counterclaimed for breach of contract and violation of A.R.S. § 23-352, he later voluntarily withdrew those claims.”
Swanson v. Image Bank, Inc., 77 P.3d 439 (Ariz. 2003). · cites it 2× “Swanson filed suit, followed by a motion for partial summary judgment, alleging breach of the employment contract and claiming TIB violated A.R.S. § 23-352 (1995) which provides that “[n]o employer may withhold or divert any portion of an employee’s wages____” In addition to…”
Hall v. A.N.R. Freight Sys., Inc., 717 P.2d 434 (Ariz. 1986). · cites it 2× “2d 51 (1983) we considered the retroactive effect of 1980 amendments to A.R.S. §§ 23-352 and 23-355, the effect of which was to sharply limit the ability of an employee to recover treble damages or attorney’s fees in a wage dispute action.”
Calisi v. Unified Fin. Servs., LLC, 302 P.3d 628 (Ariz. Ct. App. 2013). · cites it 2× “A.R.S. § 23-352(3) (2012) (employer can withhold wages if “reasonable good faith dispute” exists “as to the amount of wages due, including the amount of any counterclaim or any claim of debt, reimbursement, recoupment or set-off asserted by the employer against the employee”).”
Swanson v. Image Bank, Inc., 43 P.3d 174 (Ariz. Ct. App. 2002). · cites it 4× “¶ 18 Section 23-352, A.R.S., provides: No employer may withhold or divert any portion of an employee’s wages unless one of the following applies: 1.”
Schade v. Diethrich, 760 P.2d 1050 (Ariz. 1988). · cites it 2× “A.R.S. § 23-352; see also Abrams. The trial court’s findings and conclusions on the good faith issue are both contained in paragraph No.”
Crum v. Maricopa Cnty., 950 P.2d 171 (Ariz. Ct. App. 1997). · cites it 4× “Crum argues, however, that whatever discretion these casés attribute to the statute has been confined by an amendment to A.R.S. § 23-352(3) added by Laws 1980, Ch.”
Abrams v. Horizon Corp., 669 P.2d 51 (Ariz. 1983). · cites it 3× “In 1980, a new A.R.S. § 23-352 was added providing a specific statutory “reasonable good faith dispute” exception to A.”
Colson v. Avnet, Inc., 687 F. Supp. 2d 914 (D. Ariz. 2010). “The court also noted that § 23-352(3) “removes the remedy of treble damages when a good faith dispute regarding the amount of wages exists.”
Show all 34 citing cases →
— Ariz. Rev. Stat. § 23-352(1) — 2 cases
Sanborn v. Brooker & Wake Prop. Mgmt., Inc., 874 P.2d 982 (Ariz. Ct. App. 1994). “” A.R.S. § 23-352. In our opinion this is the proper interpretation of this exception and the only one that is consistent with prior case law, legislative intent, and the language of the statute itself.”
Swanson v. Image Bank, Inc., 43 P.3d 174 (Ariz. Ct. App. 2002). “¶ 18 Section 23-352, A.R.S., provides: No employer may withhold or divert any portion of an employee’s wages unless one of the following applies: 1.”
— Ariz. Rev. Stat. § 23-352(2) — 3 cases
Swanson v. Image Bank, Inc., 43 P.3d 174 (Ariz. Ct. App. 2002). “¶ 18 Section 23-352, A.R.S., provides: No employer may withhold or divert any portion of an employee’s wages unless one of the following applies: 1.”
United Food & Com. Workers Local 99 v. Bennett, 934 F. Supp. 2d 1167 (D. Ariz. 2013). “Finally, SB 1363 amends A.R.S. § 23-352, dealing with the withholding of wages, *1192 to forbid an employer from withholding any wages “under a written authorization from the employee past the date specified by the employee in a written revocation of the authorization.”
Mesa Airlines v. Condron (Ariz. Ct. App. 2017).
— Ariz. Rev. Stat. § 23-352(3) — 12 cases
Sanborn v. Brooker & Wake Prop. Mgmt., Inc., 874 P.2d 982 (Ariz. Ct. App. 1994). “” A.R.S. § 23-352. In our opinion this is the proper interpretation of this exception and the only one that is consistent with prior case law, legislative intent, and the language of the statute itself.”
Calisi v. Unified Fin. Servs., LLC, 302 P.3d 628 (Ariz. Ct. App. 2013). “A.R.S. § 23-352(3) (2012) (employer can withhold wages if “reasonable good faith dispute” exists “as to the amount of wages due, including the amount of any counterclaim or any claim of debt, reimbursement, recoupment or set-off asserted by the employer against the employee”).”
Crum v. Maricopa Cnty., 950 P.2d 171 (Ariz. Ct. App. 1997). “Crum argues, however, that whatever discretion these casés attribute to the statute has been confined by an amendment to A.R.S. § 23-352(3) added by Laws 1980, Ch.”
Colson v. Avnet, Inc., 687 F. Supp. 2d 914 (D. Ariz. 2010). “The court also noted that § 23-352(3) “removes the remedy of treble damages when a good faith dispute regarding the amount of wages exists.”
Patton v. Cnty. of Mohave, 741 P.2d 301 (Ariz. Ct. App. 1987).
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