Arizona Revised Statutes

Ariz. Rev. Stat. § 38-503 (2026)

Conflict of interest; exemptions; employment prohibition

✓ current as of May 2026

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A. Any public officer or employee of a public agency who has, or whose relative has, a substantial interest in any contract, sale, purchase or service to such public agency shall make known that interest in the official records of such public agency and shall refrain from voting upon or otherwise participating in any manner as an officer or employee in such contract, sale or purchase.

B. Any public officer or employee who has, or whose relative has, a substantial interest in any decision of a public agency shall make known such interest in the official records of such public agency and shall refrain from participating in any manner as an officer or employee in such decision.

C. Notwithstanding the provisions of subsections A and B of this section, no public officer or employee of a public agency shall supply to such public agency any equipment, material, supplies or services, unless pursuant to an award or contract let after public competitive bidding, except that:

1. A school district governing board may purchase, as provided in sections 15-213 and 15-323, supplies, materials and equipment from a school board member.

2. Political subdivisions other than school districts may purchase through their governing bodies, without using public competitive bidding procedures, supplies, materials and equipment not exceeding three hundred dollars in cost in any single transaction, not to exceed a total of one thousand dollars annually, from a member of the governing body if the policy for such purchases is approved annually.

D. Notwithstanding subsections A and B of this section and as provided in sections 15-421 and 15-1441, the governing board of a school district or a community college district may not employ a person who is a member of the governing board or who is the spouse of a member of the governing board.

Notes of Decisions

Cited in 16 cases (1 in the last 5 years), 1972–2021 · leading case: Hughes v. Jorgenson, 50 P.3d 821 (Ariz. 2002).

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Hughes v. Jorgenson, 50 P.3d 821 (Ariz. 2002). · cites it 16× “” In finding the language of A.R.S. § 38-503 not impermissibly vague, the court reasoned that “the term [pecuniary interest] refers to a pecuniary or proprietary interest by which a person will gain or lose something[,] as contrasted to general sympathy, feeling or bias.”

Jennings v. Woods, 982 P.2d 274 (Ariz. 1999). · cites it 22× “¶ 71 Additionally, it is argued that the general conflict of interest provisions of A.R.S. § 38-503 alone suffice. But Jones did not say this.”

State v. Ross, 151 P.3d 1261 (Ariz. Ct. App. 2007). · cites it 4× “§ 38-444 (2001) (prohibiting a public officer from asking for or receiving any gratuity or reward, except those authorized by law, "for doing [an] official act”); A.R.S. § 38-503 (2001) (requiring any public officer "who has, or whose relative has, a substantial interest in any…”

Patterson v. Maricopa Cnty. Sheriff's Off., 865 P.2d 814 (Ariz. Ct. App. 1993). · cites it 3× “Any public officer or employee who has, or whose relative has, a substantial interest in any decision of a public agency shall make known such interest in the official records of such public agency and shall refrain from participating in any manner as an officer or employee in…”

Yetman v. Naumann, 492 P.2d 1252 (Ariz. Ct. App. 1972). · cites it 7× “” The complaint further alleges that respondent is participating in the board’s decision on the petition filed by the mines contrary to our conflict of interest statute, A.R.S. § 38-503, subsec. B. The complaint then asked, inter alia, that the trial court order respondent to…”

Arizona Pub. Serv. Co. v. Long, 773 P.2d 988 (Ariz. 1989). · cites it 4× “In addition, A.R.S. § 38-503(B) requires public officers, including judges, to disqualify themselves in any matter in which they have a "substantial interest.”

Emmett McLoughlin Realty, Inc. v. Pima Cnty., 132 P.3d 290 (Ariz. Ct. App. 2006). “In particular, § 38-503(B) requires that “[a]ny public officer or employee who has .”

Maucher v. City of Eloy, 701 P.2d 593 (Ariz. Ct. App. 1985). · cites it 6× “The city contends that Maucher by his failure to heed the mandates in A.R.S. § 38-503 is estopped as a matter of public policy from enforcing the contract.”

Blue Ridge Sewer Improvement Dist. v. Lowry & Assocs., Inc., 718 P.2d 1026 (Ariz. Ct. App. 1986). · cites it 2× “In Maucher , the city violated a conflict of interest statute, A.R.S. § 38-503. The court not only found the contract formed in violation of the statute unenforceable, but it also refused to award recovery under quantum meruit.”

In Re Ethics Opinion No. 74-28, 533 P.2d 1154 (Ariz. 1975). · cites it 4× “Petitioners, as well as amici curiae, argue that the controlling standard for public officers in conflict of interest situations is set forth in A.R.S. § 38-503. They further contend that when the public policy of the State has been enunciated by the legislature in setting…”

United Farm Workers of Am., Afl-Cio v. Arizona Agric. Emp. Relations Bd., 727 F.2d 1475 (9th Cir. 1984). “See Ariz.Rev.Stat.Ann. § 38-503 (B). Indeed, it may be that the Arizona statute is stricter than the Supreme Court standard, and may prohibit the economic interest found not to be constitutionally disqualifying in Dugan v.”

Steiger v. Woods, 32 P.3d 19 (Ariz. Ct. App. 2001). · cites it 11× “This court also determined that the facts set forth in the amended complaint adequately alleged a violation of A.R.S. § 38-503 and that the trial court erred in ruling that State v.”

Castillo v. Johnson (D. Ariz. 2020). · cites it 4× “§ 1962 (c) against George Johnson, Johnson Utilities LLC, 4 Johnson International Incorporated, and James Norton for civil conspiracy to violate the 5 Arizona conflicts of interest and emoluments statutes, A.R.S. §§ 38-503(B), 38-504(C), 6 and 38-505(A)—is futile.”

Arizona Farmworkers Union v. Agric. Emp. Relations Bd., 762 P.2d 1365 (Ariz. Ct. App. 1988). · cites it 2× “A.R.S. § 38-503(B) provides that “Any public officer or employee who has, or whose relative has, a substantial interest in any decision of a public agency .”

David Welch v. Cochise Bd. of Supervisors (Ariz. 2021). “§ 38-503(A)–(B). The legislature enacted the law “to remove or limit the possibility of personal influence which might bear upon an official’s decision.”

Emmett McLoughlin Realty, Inc. v. Pima Cnty. (Ariz. Ct. App. 2006). “In particular, § 38-503(B) requires that “[a]ny public officer or employee who has .”

— Ariz. Rev. Stat. § 38-503(A) — 2 cases

Steiger v. Woods, 32 P.3d 19 (Ariz. Ct. App. 2001). “This court also determined that the facts set forth in the amended complaint adequately alleged a violation of A.R.S. § 38-503 and that the trial court erred in ruling that State v.”

— Ariz. Rev. Stat. § 38-503(B) — 8 cases

Hughes v. Jorgenson, 50 P.3d 821 (Ariz. 2002). “” In finding the language of A.R.S. § 38-503 not impermissibly vague, the court reasoned that “the term [pecuniary interest] refers to a pecuniary or proprietary interest by which a person will gain or lose something[,] as contrasted to general sympathy, feeling or bias.”

Jennings v. Woods, 982 P.2d 274 (Ariz. 1999). “¶ 71 Additionally, it is argued that the general conflict of interest provisions of A.R.S. § 38-503 alone suffice. But Jones did not say this.”

State v. Ross, 151 P.3d 1261 (Ariz. Ct. App. 2007). “§ 38-444 (2001) (prohibiting a public officer from asking for or receiving any gratuity or reward, except those authorized by law, "for doing [an] official act”); A.R.S. § 38-503 (2001) (requiring any public officer "who has, or whose relative has, a substantial interest in any…”

Arizona Pub. Serv. Co. v. Long, 773 P.2d 988 (Ariz. 1989). “In addition, A.R.S. § 38-503(B) requires public officers, including judges, to disqualify themselves in any matter in which they have a "substantial interest.”

Emmett McLoughlin Realty, Inc. v. Pima Cnty., 132 P.3d 290 (Ariz. Ct. App. 2006). “In particular, § 38-503(B) requires that “[a]ny public officer or employee who has .”

Castillo v. Johnson (D. Ariz. 2020). “§ 1962 (c) against George Johnson, Johnson Utilities LLC, 4 Johnson International Incorporated, and James Norton for civil conspiracy to violate the 5 Arizona conflicts of interest and emoluments statutes, A.R.S. §§ 38-503(B), 38-504(C), 6 and 38-505(A)—is futile.”

Arizona Farmworkers Union v. Agric. Emp. Relations Bd., 762 P.2d 1365 (Ariz. Ct. App. 1988). “A.R.S. § 38-503(B) provides that “Any public officer or employee who has, or whose relative has, a substantial interest in any decision of a public agency .”

Emmett McLoughlin Realty, Inc. v. Pima Cnty. (Ariz. Ct. App. 2006). “In particular, § 38-503(B) requires that “[a]ny public officer or employee who has .”

— Ariz. Rev. Stat. § 38-503(C) — 1 case

Maucher v. City of Eloy, 701 P.2d 593 (Ariz. Ct. App. 1985). “The city contends that Maucher by his failure to heed the mandates in A.R.S. § 38-503 is estopped as a matter of public policy from enforcing the contract.”

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