Arizona Revised Statutes

Ariz. Rev. Stat. § 40-241 (2026)

Power to examine records and personnel of public service corporations; filing record of examination

✓ current as of May 2026

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A. The commission, each commissioner and person employed by the commission may, at any time, inspect the accounts, books, papers and documents of any public service corporation, and any of such persons who are authorized to administer oaths may examine under oath any officer, agent or employee of such corporation in relation to the business and affairs of the corporation.

B. Any person other than a commissioner or an officer of the commission demanding such inspection shall produce under the hand and seal of the commission his authority to make the inspection.

C. A written record of such testimony or statement given under oath shall be made and filed with the commission.

Notes of Decisions

Cited in 10 cases (3 in the last 5 years), 1978–2022 · leading case: Campbell v. Mountain States Tel. & Tel. Co., 586 P.2d 987 (Ariz. Ct. App. 1978).

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Campbell v. Mountain States Tel. & Tel. Co., 586 P.2d 987 (Ariz. Ct. App. 1978). · cites it 8× “FACTS AND ISSUES The primary question raised by this appeal is whether A.R.S. § 40-241 et seq., and § 40-321 et seq.”

Qwest Corp. v. Kelly, 59 P.3d 789 (Ariz. Ct. App. 2002). · cites it 5× “§§ 40-241 and 40-321, 2 or the doctrine of primary jurisdiction required the plaintiff to present tort and breach of contract claims against Mountain States Telephone & Telegraph Company (Mountain States) to the Commission before she could file a lawsuit alleging those claims in…”

S. Union Co. v. Sw. Gas Corp., 415 F.3d 1001 (9th Cir. 2005). · cites it 2× “” Ariz. Rev. Stat. § 40-241 . In this case, the jury had evidence before it from which it could have determined that Irvin’s actions, though misguided, were designed to further the interests of the Commission and of the State.”

Metro Mobile CTS, Inc. v. Newvector Commc'ns, Inc., 661 F. Supp. 1504 (D. Ariz. 1987). “at section 40-241(A). Second, the ACC has adjudicatory powers.”

Robert Burns v. Arizona Pub. Serv. Co (Ariz. 2022). · cites it 12× “Subsequently, Burns requested and received an opinion from the Attorney General, who concluded that A.R.S. § 40-241 confers power on individual commissioners to “gather information regarding a PSC’s political and charitable contributions, and lobbying expenditures, by inspecting…”

Burns v. Apsc (Ariz. Ct. App. 2021). · cites it 4× “Opinion of the Court methods and affairs of corporations under A.R.S. § 40-241(A) apply to [Pinnacle West] as well as to APS .”

Qwest Corp. v. Mark McMahon (Ariz. Ct. App. 2002). · cites it 5× “§§ 40-241 and 40-321,2 or the doctrine of primary jurisdiction required the plaintiff to present tort and breach of contract claims against Mountain States Telephone & Telegraph Company (Mountain States) to the Commission before she could file a lawsuit alleging those claims in…”

Woodward v. Acc (Ariz. Ct. App. 2018). · cites it 2× “” ¶31 Hearings before the Commission are governed by A.R.S. §§ 40-241 to -56 and “by rules of practice and procedure adopted by the [C]ommission.”

S. Union Co. v. Irvin (9th Cir. 2005). “” Ariz. Rev. Stat. § 40-241 . In this case, the jury had evidence before it from which it could have determined that Irvin’s actions, though misguided, were designed to further the interests of the Commission and of the State.”

— Ariz. Rev. Stat. § 40-241(A) — 4 cases

Metro Mobile CTS, Inc. v. Newvector Commc'ns, Inc., 661 F. Supp. 1504 (D. Ariz. 1987). “at section 40-241(A). Second, the ACC has adjudicatory powers.”

Robert Burns v. Arizona Pub. Serv. Co (Ariz. 2022). “Subsequently, Burns requested and received an opinion from the Attorney General, who concluded that A.R.S. § 40-241 confers power on individual commissioners to “gather information regarding a PSC’s political and charitable contributions, and lobbying expenditures, by inspecting…”

Burns v. Apsc (Ariz. Ct. App. 2021). “Opinion of the Court methods and affairs of corporations under A.R.S. § 40-241(A) apply to [Pinnacle West] as well as to APS .”

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