Arizona Revised Statutes
Ariz. Rev. Stat. § 32-2152 (2026)
Action by broker or salesperson to collect compensation
✓ current as of May 2026
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A. An action for the collection of compensation earned may be maintained in the courts of the state by any broker or salesperson. To commence the action the complaint shall allege that the plaintiff was a qualified licensed broker or salesperson at the time the claim arose. Prior to hearing the action the court shall require the plaintiff to prove the alleged qualifications.
B. The commissioner shall not entertain complaints regarding purely civil disputes between licensees concerning the earning, splitting or nonpayment of compensation.
C. Nothing in this section shall be construed to permit the payment or receipt of compensation in violation of sections 32-2155 or 32-2163.
Notes of Decisions
Cited in 19
cases (1 in the last 5 years), 1958–2024 · leading case: Mousa v. Saba, 218 P.3d 1038 (Ariz. Ct. App. 2009).
Mousa v. Saba, 218 P.3d 1038 (Ariz. Ct. App. 2009). “Arizona Funds moved to dismiss on the ground that the services for which Mousa was seeking compensation required a real estate salesperson’s or broker’s license and that under AR.S. § 32-2152, Mousa could not bring such a claim because he lacked either license.”
Focus point/kantor v. johnson/oak Acres, 330 P.3d 360 (Ariz. Ct. App. 2014). “¶ 17 Johnson/Oak Acres contend the trial court erred under A.R.S. § 32-2152(A) by ruling that Kantor could initiate and maintain a lawsuit for a real estate commission notwithstanding evidence that he violated Arizona law by not timely disclosing to ADRE that he had violated a…”
Ness v. Greater Arizona Realty, Inc., 572 P.2d 1195 (Ariz. Ct. App. 1977). “Mangels claims that Grutzmacher cannot sue for his share of the commission because Grutzmacher was not licensed in Arizona on December 3, 1970, as required by A.R.S. § 32-2152, which states: “Action by broker or salesman to collect compensation An action for the collection of…”
Adams Realty Corp. v. Realty Ctr. Investments, Inc., 719 P.2d 291 (Ariz. Ct. App. 1986). “We have specifically held that, under A.R.S. §§ 32-2152 2 and 2155, an unlicensed real estate salesperson may not bring suit to recover a broker’s commission for services requiring a license.”
Wright v. Hills, 780 P.2d 416 (Ariz. Ct. App. 1989). “See A.R.S. § 32-2152. The motion filed by the defendants Alma School, the Jacksons and the Urbans also contended that Wright admitted in his deposition to certain facts which showed, as a matter of law, that there was no fraudulent transfer of the land.”
Bonasera v. Roffe, 442 P.2d 165 (Ariz. Ct. App. 1968). “On appeal, Bonasera maintains that the trial court erred in holding that A.R.S. § 32-2152 rendered the agreement unenforceable.”
Bustrum v. Gardner, 743 P.2d 5 (Ariz. Ct. App. 1987). “Appellee argued that because Bustrum was only licensed in California, A.R.S. § 32-2152 prohibited Bustrum from maintaining an action to collect the unpaid commission.”
Hall v. Bowman, 357 P.2d 149 (Ariz. 1960). “It further appears on the face of the complaint that this is an action for the collection of compensation earned from the sale of cemetery property and that therefore this action comes within the provisions of A.R.S. § 32-2152 which provides as follows: “An action for the…”
Realty Executives, Inc. v. Northrup, King & Co., 539 P.2d 514 (Ariz. Ct. App. 1975). “Realty first points out that it was properly licensed at all times and therefore it fully complied with A.R.S. § 32-2152, which states: “An action for the collection of compensation earned may be maintained in the courts of .”
Farragut Baggage & Transfer Co. v. Shadron Realty Inc., 501 P.2d 38 (Ariz. Ct. App. 1972). “It is true that A.R.S. § 32-2152 requires the plaintiffs to plead and prove, as a condition precedent to recovery of the commission, that he was licensed at the time the claim arose.”
Maganas v. Northroup, 537 P.2d 595 (Ariz. 1975). “The second question, and the one which we think is determinative of this appeal, is whether appellant is barred from collecting a commission because of noncompliance with licensing provisions of Arizona’s Securities Act.”
Weir v. Galbraith, 376 P.2d 396 (Ariz. 1962). “A.R.S. § 32-2152. “Action by broker or salesman to collect compensation.”
— Ariz. Rev. Stat. § 32-2152(A) — 4 cases
Mousa v. Saba, 218 P.3d 1038 (Ariz. Ct. App. 2009). “Arizona Funds moved to dismiss on the ground that the services for which Mousa was seeking compensation required a real estate salesperson’s or broker’s license and that under AR.S. § 32-2152, Mousa could not bring such a claim because he lacked either license.”
Focus point/kantor v. johnson/oak Acres, 330 P.3d 360 (Ariz. Ct. App. 2014). “¶ 17 Johnson/Oak Acres contend the trial court erred under A.R.S. § 32-2152(A) by ruling that Kantor could initiate and maintain a lawsuit for a real estate commission notwithstanding evidence that he violated Arizona law by not timely disclosing to ADRE that he had violated a…”
Com./cra v. Zinke (Ariz. Ct. App. 2014).
Kode v. United Dental Corp. (D. Ariz. 2024).
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