Fernandez v. Takata Seat Belts, Inc., 108 P.3d 917 (Ariz. 2005). · Go Syfert
Fernandez v. Takata Seat Belts, Inc., 108 P.3d 917 (Ariz. 2005). Cases Citing This Book View Copy Cite
G Cite
cited 3× by 3 distinct cases · …rigorous standing requirement, at p. 919
64 citation events (64 in the last 25 years) across 5 distinct courts.
Treatment trajectory · 2005 → 2026 · click a year to view as-of
2005 2015 2026
Top citers, strongest first. 31 distinct citers. How cited ↗
discussed Cited as authority (verbatim quote) Taylor v. Flagstaff, City of
D. Ariz. · 2019 · quote attribution · 1 verbatim quote · confidence high
although we are not bound by 27 federal jurisprudence on the matter of standing, we have previously found federal case law 28 instructive.
discussed Cited as authority (rule) Republican National Committee; Republican Party of Arizona v. Adrian Fontes; Voto Latino
Ariz. Ct. App. · 2025 · confidence medium
Instead, standing “only raises ‘questions of prudential or judicial restraint.’” Strawberry Water Co., 220 Ariz. 401, ¶ 7 (quoting Armory Park Neighborhood Ass’n, 148 Ariz. at 6 ). 5 REPUBLICAN NAT’L COMM. v. FONTES Opinion of the Court ¶11 Nonetheless, Arizona has “established a rigorous standing requirement.” Fernandez v. Takata Seat Belts, Inc., 210 Ariz. 138, ¶ 6 (2005).
discussed Cited as authority (rule) Hernandez v. Costco Wholesale Corporation
D. Ariz. · 2022 · confidence medium
The Ninth Circuit recognizes an exception to 28 this requirement where there is “absolute certainty that remand would prove futile.” Bell 1|| v. City of Kellogg, 922 F.2d 1418, 1425 (9th Cir. 1991) Gnternal quotation omitted). 2 Arizona does not have a counterpart to Article III’s case or controversy requirement. 3|| Fernandez v. Takata Seat Belts, Inc., 108 P.3d 917, 919 (Ariz. 2005).
cited Cited as authority (rule) Edmonds v. 9540
Ariz. Ct. App. · 2021 · confidence medium
Fernandez v. Takata Seat Belts, Inc., 210 Ariz. 138, 140, ¶ 6 (2005).
discussed Cited as authority (rule) Strojnik v. Kashyap
Ariz. Ct. App. · 2021 · confidence medium
Cimarron Foothills Cmty. Ass’n v. Kippen, 206 Ariz. 455, 458, ¶ 6 (App. 2003). ¶7 The first element of standing requires Strojnik to have “a distinct and palpable injury.” See Fernandez v. Takata Seat Belts, Inc., 210 Ariz. 138, 140, ¶ 6 (2005) (citation omitted).
discussed Cited as authority (rule) Strojnik v. Flagexpress, LLC
Ariz. Ct. App. · 2021 · confidence medium
Cimarron Foothills Cmty. Ass’n v. Kippen, 206 Ariz. 455, 458, ¶ 6 (App. 2003). ¶7 The first element of standing requires Strojnik to have “a distinct and palpable injury.” See Fernandez v. Takata Seat Belts, Inc., 210 Ariz. 138, 140, ¶ 6 (2005) (citation omitted).
discussed Cited as authority (rule) Laws v. Grayeyes
Utah · 2021 · confidence medium
For example, Arizona has recognized that ―the question of standing in Arizona is not a constitutional mandate since [that state] ha[s] no counterpart to the ‗case or controversy‘ requirement of the federal constitution.‖ Fernandez v. Takata Seat Belts, Inc., 108 P.3d 917, 919 (Ariz. 2005) (citation omitted).
discussed Cited as authority (rule) Strojnik v. Pro Hospitality One PV LLC
D. Ariz. · 2021 · confidence medium
Upon review over the claims in this matter, the 6 || Court concludes that, while it is highly likely the state court would dismiss Plaintiff’s ADA 7 || claim in Count | for failure to meet its own “rigorous standing requirement,” see Fernandez || v. Takata Seat Belts, Inc., 108 P.3d 917, 919 (Ariz. 2005), it cannot say that result is 9|| “certain,” as required by the Ninth Circuit in Bell.
discussed Cited as authority (rule) Strojnik v. WMH Enterprises LLC
D. Ariz. · 2021 · confidence medium
Upon review over the claims in this matter, the 22 Court concludes that, while it is highly likely the state court would dismiss Plaintiff’s ADA 23 claim in Count 1 for failure to meet its own “rigorous standing requirement,” see Fernandez 24 v. Takata Seat Belts, Inc., 108 P.3d 917, 919 (Ariz. 2005), it cannot say that result is 25 “certain,” as required by the Ninth Circuit in Bell.
discussed Cited as authority (rule) Strojnik v. Kingman Investments LP
D. Ariz. · 2021 · confidence medium
Upon review over the claims in this matter, the || Court concludes that, while it is highly likely the state court would dismiss Plaintiff's ADA 3 || claim in Count | for failure to meet its own “rigorous standing requirement,” see Fernandez v. Takata Seat Belts, Inc., 108 P.3d 917, 919 (Ariz. 2005), it cannot say that result is “certain,” as required by the Ninth Circuit in Bell.
discussed Cited as authority (rule) Strojnik v. Payson Hospitality Group LLC
D. Ariz. · 2021 · confidence medium
Upon review over the claims in this matter, the 11 || Court concludes that, while it is highly likely the state court will dismiss Plaintiff’s ADA 12 || claim in Count | for failure to meet its own “rigorous standing requirement,” see Fernandez 13 || v. Takata Seat Belts, Inc., 108 P.3d 917, 919 (Ariz. 2005), it cannot say that result is 14]| “certain,” as required by the Ninth Circuit in Bell.
discussed Cited as authority (rule) Strojnik v. Forest Villas Inn II LLC
D. Ariz. · 2021 · confidence medium
Polo, 833 F.3d at 1198 (under Bell, futility exists if there is an “absolute 18 certainty that a state court would simply dismiss the action on remand”) (cleaned up). 19 Although the complaint largely identifies barriers at Forest Villas’ facility that might 20 interfere with a wheelchair-bound customer’s ability to enjoy full and equal access to the 21 facility, Strojnik doesn’t allege that he was using a wheelchair during his visit. 22 The bottom line is that Arizona courts “have established a rigorous standing 23 requirement,” which requires a plaintiff to “allege a distinct…
cited Cited as authority (rule) Villa De Jardines Association v. Flagstar Bank, Federal National Mortgage Assoc.
Ariz. Ct. App. · 2011 · confidence medium
The only authority VJA provides in support of its position is Fernandez v. Takata Seat Belts, Inc., 210 Ariz. 138, ¶ 6 , 108 P.3d 917, 919 (2005).
cited Cited as authority (rule) Villa De Jardines Ass'n v. Flagstar Bank, FSB
Ariz. Ct. App. · 2011 · confidence medium
The only authority VJA provides in support of its position is Fernandez v. Takata Seat Belts, Inc., 210 Ariz. 138, ¶ 6 , 108 P.3d 917, 919 (2005).
discussed Cited as authority (rule) Baier v. Mayer Unified School District (2×)
Ariz. Ct. App. · 2010 · confidence medium
Because Arizona has no counterpart to the federal “ease or controversy” requirement, “the question of standing in Arizona is not a constitutional mandate.” Fernandez v. Takata Seat Belts, Inc., 210 Ariz. 138, 141, ¶ 6 , 108 P.3d 917, 919 (2005) (quoting Armory Park Neighborhood Ass’n v. Episcopal Cmty. Servs. in Ariz., 148 Ariz. 1, 6 , 712 P.2d 914, 919 (1985)).
discussed Cited as authority (rule) ARIZONA ASSOCIATION OF PROVIDERS v. State (2×)
Ariz. Ct. App. · 2009 · confidence medium
Fernandez v. Takata Seat Belts, Inc., 210 Ariz. 138, 140, ¶ 6 , 108 P.3d 917, 919 (2005). ¶ 17 To establish standing, Plaintiffs must allege a "distinct and palpable injury." Id.
discussed Cited as authority (rule) Arizona Ass'n of Providers for Persons with Disabilities v. State (2×)
Ariz. Ct. App. · 2009 · confidence medium
Fernandez v. Takata Seat Belts, Inc., 210 Ariz. 138, 140, ¶ 6 , 108 P.3d 917, 919 (2005). ¶ 17 To establish standing, Plaintiffs must allege a “distinct and palpable injury.” Id.
discussed Cited as authority (rule) Mayer Unified School District v. Winkleman
Ariz. Ct. App. · 2008 · confidence medium
Because Arizona has no counterpart to the federal “case or controversy” requirement, “‘the question of standing *388 ... is not a constitutional mandate.’ ” Fernandez v. Takata Seat Belts, Inc., 210 Ariz. 138, ¶ 6 , 108 P.3d 917, 919 (2005), quoting Armory Park Neighborhood Ass’n v. Episcopal Cmty. Servs. in Ariz., 148 Ariz. 1, 6 , 712 P.2d 914, 919 (1985).
examined Cited as authority (rule) Home Builders Ass'n of Cent. Ariz. v. Kard (3×)
Ariz. Ct. App. · 2008 · confidence medium
Fernandez v. Takata Seat Belts, Inc., 210 Ariz. 138, 140, ¶ 6 , 108 P.3d 917, 919 (2005).
discussed Cited as authority (rule) Mayer Unified School and Gadsen Elementary School v. Winkleman, Az State Land Dept...
Ariz. Ct. App. · 2008 · confidence medium
Because Arizona has no counterpart to the federal “case or controversy” requirement, “‘the question of standing . . . is not a constitutional mandate.’” Fernandez v. Takata Seat Belts, Inc., 210 Ariz. 138, ¶ 6 , 108 P.3d 917, 919 (2005), quoting Armory Park Neighborhood Ass’n v. Episcopal Cmty. Servs. in Ariz., 148 Ariz. 1, 6 , 712 P.2d 914, 919 (1985).
examined Cited as authority (rule) Bennett v. Brownlow (3×)
Ariz. · 2005 · confidence medium
E.g., Fernandez v. Takata Seat Belts, Inc., 210 Ariz. 138, 140, ¶ 6 , 108 P.3d 917, 919 (2005); Bennett v. Napolitano (“Napolitano ”), 206 Ariz. 520, 525, ¶ 19 , 81 P.3d 311, 316 (2003).
cited Cited "see" Knight v. Mohave
Ariz. Ct. App. · 2026 · signal: see · confidence high
See Fernandez v. Takata Seat Belts, Inc., 210 Ariz. 138 , 141 ¶ 13 (2005) (plaintiff must have viable claim against defendant to press a class action).
cited Cited "see" Erlick v. Davis
Ariz. Ct. App. · 2023 · signal: see · confidence high
See Fernandez v. Takata Seat Belts, Inc., 210 Ariz. 138 , 140 ¶ 6 (2005).
cited Cited "see" Strojnik v. Driftwood Hospitality Management LLC
D. Ariz. · 2021 · signal: see · confidence high
See Advocs. for Individuals With Disabilities 1|| LLC, 279 F. Supp. 3d at 897 (quoting Fernandez v. Takata Seat Belts, Inc., 108 P.3d 917 , 2|| 919 (Ariz. 2005)).
cited Cited "see" Montelongo-Morales v. Driscoll
Ariz. Ct. App. · 2020 · signal: see · confidence high
See Fernandez v. Takata Seat Belts, Inc., 210 Ariz. 138, 141, ¶ 10 (2005).
discussed Cited "see" Mirchandani v. Bmo
Ariz. Ct. App. · 2016 · signal: see · confidence high
See Fernandez v. Takata Seat Belts, Inc., 210 Ariz. 138, 140, ¶ 6 (2005) (citation omitted). ¶14 Mirchandani argues that he has a direct stake in the outcome of the litigation because he personally guaranteed the loans and because Quality was a “closely held LLC.” However, although a guarantor who has paid upon his principal’s debt has an immediate right of action against the principal, affirmative recovery by the guarantor against a third party would exceed the scope of the surety relationship and “usurp claims belonging only to the principal.” Schroeder v. Hudgins, 142 Ariz. 395,…
discussed Cited "see" Eden v. Show Low (2×)
Ariz. Ct. App. · 2015 · signal: see · confidence high
See Fernandez v. Takata Seat Belts, Inc., 210 Ariz. 138, 140, ¶ 6 , 108 P.3d 917, 919 (2005); Strawberry Water Co. v. Paulsen, 220 Ariz. 401, 405-06, ¶¶ 7-8 , 207 P.3d 654, 658-59 (App. 2008).
discussed Cited "see" Master Financial, Inc. v. Crowder (2×)
Md. · 2009 · signal: see · confidence high
See Fernandez v. Takata, 210 Ariz. 138 , 108 P.3d 917, 920 (2005); Hammond v. Florida Asset Financing Corporation, 695 N.W.2d 1, 5-6 (Iowa 2005); State v. Madden, 204 W.Va. 606 , 515 S.E.2d 351 , 354-55 (1998).
discussed Cited "see" Karbal v. Arizona Department of Revenue (2×)
Ariz. Ct. App. · 2007 · signal: see · confidence high
See Fernandez v. Takata Seat Belts, Inc., 210 Ariz. 138, 141, ¶¶ 12-13 , 108 P.3d 917, 920 (2005). ¶ 7 The question of standing in Arizona does not raise constitutional concerns because, unlike the United States Constitution, Arizona’s constitution contains no case or controversy requirement.
discussed Cited "see, e.g." Arizona City Sanitary Dist. v. Pinal County (2×)
Ariz. Ct. App. · 2010 · signal: see also · confidence low
See Karbal v. Arizona Dep’t of Rev., 215 Ariz. 114, ¶ 7 , 158 P.3d 243, 245 (App. 2007); see also Fernandez v. Takata Seat Belts, Inc., 210 Ariz. 138, ¶ 6 , 108 P.3d 917, 919 (2005).
discussed Cited "see, e.g." Arizona City Sanitary District v. Olson (2×)
Ariz. Ct. App. · 2010 · signal: see also · confidence low
See Karbal v. Arizona Dep’t of Rev., 215 Ariz. 114, ¶ 7 , 158 P.3d 243, 245 (App.2007); see also Fernandez v. Takata Seat Belts, Inc., 210 Ariz. 138, ¶ 6 , 108 P.3d 917, 919 (2005).
Retrieving the full opinion text from the archive…
Eleanora FERNANDEZ, Individually and on Behalf of All Similarly Situated Persons, Plaintiff-Appellant,
v.
TAKATA SEAT BELTS, INC., Nissan North America, Inc.; General Motors Corporation; Ford Motor Company; DaimlerChrysler Corporation; SGS U.S. Testing Company, Inc., Defendants-Appellees
CV-04-0277-PR.
Arizona Supreme Court.
Mar 24, 2005.
108 P.3d 917
Rake & Catanese, PC, by David J. Cata-nese, Phoenix, Attorneys for Plaintiff-Appellant., Bowman & Brooke, LLP, by Paul G. Cere-ghini, Jill S. Goldsmith, James C. Goodwin, Phoenix, Attorneys for Defendants-Appel-lees Takata Seat Belts, Inc., General Motors Corporation, and Nissan North America, Inc., Carpenter & Lipps LLP, by Michael H. Carpenter, Columbus, Ohio, Attorneys for Defendant-Appellee Takata Seat Belts, Inc., Snell & Wilmer LLP, by Martha E. Gibbs, Gregory J. Marshall, Phoenix and O’Melveny & Myers LLP, by Brian C. Anderson, Washington, D.C., Attorneys for Defendant-Ap-pellee Ford Motor Company., Snell & Wilmer LLP, by Patrick X. Fowler, Phoenix and Hogan & Hartson, LLP, by Lewis H. Goldfarb, Christopher B. Wren, New York, New York, Attorneys for Defendant-Appellee DaimlerChrysler Corporation., Keller Rohrbaek, PLC, by Leon B. Silver, Phoenix, Attorneys for Defendant-Appellee SGS U.S. Testing Company, Inc., Pacific Legal Foundation, by Deborah J. La Fetra, Gregory T. Broderick, Sacramento, California, Attorneys for Amicus Curiae Pacific Legal Foundation.
Ryan, Jones, McGregor, Berch, Hurwitz.
Cited by 32 opinions  |  Published
Pinpoint authority: bottom 52%

OPINION

RYAN, Justice.

¶ 1 In this case, we must decide whether a plaintiff who has no individual claim against a defendant may allege class action claims against that defendant and require the defendant to remain as a party to the lawsuit because she seeks to represent a class of other purported plaintiffs, some of whom may have claims against the defendant.

I

¶2 Eleanora Fernandez brought a class action lawsuit [1] against, among others, Taka-ta Seat Belts, SGS U.S. Testing Company, Inc., Nissan North America, General Motors Corporation, Ford Motor Company, and Da-imlerChrysler Corporation. She alleged fraudulent concealment, violation of the Arizona Consumer Fraud Act, unjust enrichment, and constructive trust. Fernandez claimed that between 1986 and 1999, several automobile manufacturers installed in their vehicles TK-52 seatbelt buckles manufactured by Takata and tested by SGS U.S. Testing. She alleged that the TK-52 buckles were defective because they could disengage in accidents. She also contended that all of the defendants knew about this supposed defect and that they concealed this risk from consumers.

¶ 3 The complaint did not specify the make or model of the automobile Fernandez owned. But she later conceded that she did not own a Nissan, General Motors, Ford, or DaimlerChrysler vehicle. These four automobile manufacturers filed a motion to dismiss for “failure to state a claim upon which relief can be granted.” Ariz. R. Civ. P. 12(b)(6). The superior court dismissed all of Fernandez’s claims, concluding that she had failed to allege essential elements of each of her four claims.

[*140] ¶ 4 Fernandez appealed. The court of appeals affirmed the trial court’s dismissal of her individual claims against the four automobile manufacturers. Fernandez v. Takata Seat Belts, et al., 1-CA-CV 03-0473, ¶¶ 11-12 (Ariz.App. June 10, 2004) (mem.decision). Under the standard of review for a motion to dismiss, however, the court stated that “until such time as the trial court issues an order determining whether a class action can be maintained in this case,” it would “decline to review the viability of Plaintiffs class action claims against the automobile manufacturers in her representative capacity.” Id. at ¶ 13.

¶ 5 The automobile manufacturers petitioned for review, [2] contending that Fernandez’s “inability to assert individual claims against the automobile manufacturers precludes her from suing” them “on behalf of a proposed class.” We granted review because this is a matter of first impression for this court. We have jurisdiction under Article 6, Section 5(3), of the Arizona Constitution, Arizona Revised Statutes (“A.R.S.”) section 12-120.24 (2003), and Rule 23 of the Arizona Rules of Civil Appellate Procedure.

II

A

¶ 6 We have previously concluded that “the question of standing in Arizona is not a constitutional mandate since we have no counterpart to the ‘ease or controversy’ requirement of the federal constitution,” Armory Park Neighborhood Ass’n v. Episcopal Cmty. Servs. in Ariz., 148 Ariz. 1, 6, 712 P.2d 914, 919 (1985) (citing State v. B Bar Enters., 133 Ariz. 99, 649 P.2d 978 (1982)), and thus, when addressing questions of standing “we are confronted only with questions of prudential or judicial restraint.” Id. Nonetheless, we have established a rigorous standing requirement. “To gain standing to bring an action, a plaintiff must allege a distinct and palpable injury.” Sears v. Hull, 192 Ariz. 65, 69, ¶ 16, 961 P.2d 1013, 1017 (1998) (citing Warth v. Seldin, 422 U.S. 490, 501, 95 S.Ct. 2197, 45 L.Ed.2d 343 (1975)). We will consider the merits of a case without such an injury “only in exceptional circumstances, generally in cases involving issues of great public importance that are likely to recur. The paucity of eases in which we have waived the standing requirement demonstrates both our reluctance to do so and the narrowness of this exception.” Hull, 192 Ariz. at 71, ¶ 25, 961 P.2d at 1019.

¶ 7 Fernandez admits that she has never owned any vehicle manufactured by defendants. Instead, she owns or owned an automobile manufactured by Honda, which is not a party to the lawsuit. [3] Moreover, Fernandez has not alleged that she has suffered any injury, either physical or economic, “fairly traceable” to the conduct of the four defendant automobile manufacturers. See Bennett v. Napolitano, 206 Ariz. 520, 525, ¶ 18, 81 P.3d 311, 316 (2003) (“To establish federal standing, a party invoking the court’s jurisdiction must allege personal injury fairly traceable to the defendant’s allegedly unlawful conduct and likely to be redressed by the requested relief.”) (citing Allen v. Wright, 468 U.S. 737, 751, 104 S.Ct. 3315, 82 L.Ed.2d 556 (1984)); see also Easter v. American W. Fin., 381 F.3d 948, 961 (9th Cir.2004) (holding that “[t]o satisfy the traceability requirement, a class action plaintiff must ‘allege a distinct and palpable injury to himself, even if it is an injury shared by a large class of other possible litigants’ ”) (quoting Warth, 422 U.S. at 501, 95 S.Ct. 2197). Accordingly, because Fernandez cannot allege “a distinct and palpable injury” resulting from any conduct of the four automobile manufacturers, she has no standing to bring an individual claim against them. Hull, 192 Ariz. at 69, ¶ 16, 961 P.2d at 1017.

¶ 8 The court of appeals therefore properly affirmed the dismissal of her individual claims against the four automobile manufae-[*141] turers. Fernandez, 1-CA-CV 03-0473, mem. dec. at 12.

B

¶ 9 Fernandez nonetheless contends that because she owns or did own a Honda, which allegedly has one of the defective TK-52 series seatbelt buckles, she has standing to represent a class of people who actually own automobiles manufactured by one of the automobile manufacturer defendants in this case.

¶ 10 Because a plaintiff who cannot allege that a defendant inflicted a distinct and palpable injury on her cannot sue that defendant, Hull, 192 Ariz. at 69, ¶ 16, 961 P.2d at 1017, it logically follows that the same plaintiff should not be able to sue that defendant by bringing a class action purporting to represent a class of people who actually were harmed by the defendant. To permit a plaintiff to do that would severely weaken, if not entirely eliminate, our standing requirement.

¶ 11 “Although we are not bound by federal jurisprudence on the matter of standing, we have previously found federal case law instructive.” Bennett, 206 Ariz. at 525, ¶ 22, 81 P.3d at 316 (citing Armory Park, 148 Ariz. at 6, 712 P.2d at 919). With respect to the issue presented by this case, several United States Supreme Court decisions are instructive.

¶ 12 The Court has held that “if none of the named plaintiffs purporting to represent a class establishes the requisite of a case or controversy with the defendants, none may seek relief on behalf of himself or any other member of the class.” O’Shea v. Littleton, 414 U.S. 488, 494, 94 S.Ct. 669, 38 L.Ed.2d 674 (1974). In addition, the Court has stressed that named plaintiffs in class actions “must allege and show that they personally have been injured, not that injury has been suffered by other, unidentified members of the class to which they belong and which they purport to represent.” Warth, 422 U.S. at 502, 95 S.Ct. 2197; see also Lewis v. Casey, 518 U.S. 343, 357, 116 S.Ct. 2174, 135 L.Ed.2d 606 (1996) (standing requirements are “no less true with respect to class actions than with respect to other suits”); Simon v. Eastern Ky. Welfare Rights Org., 426 U.S. 26, 40 n. 20, 96 S.Ct. 1917, 48 L.Ed.2d 450 (1976) (“That a suit may be a class action, however, adds nothing to the question of standing____”); Allee v. Medrano, 416 U.S. 802, 828-29, 94 S.Ct. 2191, 40 L.Ed.2d 566 (1974) (“[A] named plaintiff cannot acquire standing to sue by bringing his action on behalf of others who suffered injury which would have afforded them standing had they been named plaintiffs; it bears repeating that a person cannot predicate standing on injury which he does not share. Standing cannot be acquired through the back door of a class action.”) (Burger, C.J., concurring in the result in part and dissenting in part). Given that our class action rule mirrors the federal rule, [4] we find these Supreme Court cases persuasive in deciding the issue presented by this case.

¶ 13 We hold, therefore, that the proper inquiry in a class action lawsuit must initially focus on whether the plaintiff has an individual claim against the defendant. If she does not, she cannot maintain a class action against that defendant. See Easter, 381 F.3d at 962 (holding that District Court properly addressed standing before addressing issue of class certification). Because Fernandez has no individual claim against the defendant automobile manufacturers, she does not have standing to bring a class action against them.

Ill

¶ 14 Fernandez argues that under the “juridical link” doctrine, she should be permitted to pursue her class action against the automobile manufacturers. [5] We disagree.

¶ 15 The juridical link doctrine was first articulated in dicta in LaMar v. H & B Novelty & Loan Co., 489 F.2d 461, 470 (9th Cir.1973). Another court explained LaMar’s discussion of the doctrine as follows:

[*142] LaMar held that a plaintiff without a cause of action against a specific defendant cannot “ ‘fairly and adequately protect the interests of those who do have such causes of action,” for purposes of Rule 23(a). Nevertheless ... the court went on to hold that if the plaintiffs as a group — named and unnamed — have suffered an identical injury at the hands of several parties related by way of a conspiracy or concerted scheme, or otherwise “juridically related in a manner that suggests a single resolution of the dispute would be expeditious,” the claim could go forward.

Payton v. County of Kane, 308 F.3d 673, 678-79 (7th Cir.2002) (citations omitted).

¶ 16 Federal case law after LaMar has largely limited the application of the doctrine to circumstances in which “all the defendants took part in a similar scheme that was sustained either by a contract or conspiracy, or was mandated by a uniform state rule,” such that it was “appropriate to join as defendants even parties with whom the named class representative did not have direct contact.” Id. at 679 (original emphasis); Moore v. Comfed Sav. Bank, 908 F.2d 834, 838 (11th Cir.1990) (commenting that in most cases in which a juridical link was found, “there was either a contractual obligation among all defendants or a state or local statute requiring common action by the defendants”); In re Itel Sec. Litig., 89 F.R.D. 104, 121 (N.D.Cal.1981) (juridical link “refers to some type of legal relationship which relates all defendants in a way that would make single resolution of a dispute preferable to a multiplicity of similar actions”). For instance, some courts have found a juridical link when multiple government agencies or officers apply a common rule that is the subject of legal challenge. See Matte v. Sunshine Mobile Homes, Inc., 270 F.Supp.2d 805, 827 (W.D.La.2003); see also Murer v. Montana State Comp. Mut. Ins. Fund, 257 Mont. 434, 849 P.2d 1036, 1039 (1993) (finding that a “juridical link [exists] where the various defendants are related instrumentalities of a single state, such as various law enforcement agencies”).

¶ 17 Even if we were to adopt the juridical link doctrine, we would conclude that the doctrine does not confer standing on Fernandez under the circumstances of this case. Fernandez does not allege a conspiracy or concerted action between the automobile manufacturers, nor does she allege that they had some legal relationship. See, e.g., Easter, 381 F.3d at 962 (finding that juridical link doctrine did not apply because plaintiffs “presented no evidence that their alleged injuries were the result of a conspiracy or concerted scheme between the ... [defendants]”); Alexander v. PSB Lending Corp., 800 N.E.2d 984, 993 (Ind.Ct.App.2003) (concluding that because plaintiffs did not allege any “contractual relationship, concerted conduct, or conspiracy’ between defendants with whom named plaintiffs did not have direct contact, application of the juridical link doctrine was not warranted).

IV

¶ 18 Finally, “[although, as a matter of discretion, we can waive the requirement of standing, we do so only in exceptional circumstances, generally in cases involving issues of great public importance that are likely to recur.” Hull, 192 Ariz. at 71, ¶ 25, 961 P.2d at 1019. Fernandez, however, has presented no circumstance that persuades us to waive the requirement of standing. She does not contend that her case concerns a matter of statewide importance, involves constitutional questions, or presents issues of such great public importance that we should exercise our discretion and waive standing for her class action claims. Id. at 71-72, ¶¶ 25-29, 961 P.2d at 1019-20.

V

¶ 19 For the foregoing reasons, we vacate in part the decision of the court of appeals and affirm the ruling of the trial court dismissing the automobile manufacturers from the lawsuit.

CONCURRING: CHARLES E. JONES, Chief Justice, RUTH V. McGREGOR, Vice Chief Justice, REBECCA WHITE BERCH and ANDREW D. HURWITZ, Justices.
2

. Although all defendants, including Takata and SGS U.S. Testing, petitioned for review on a number of issues, we granted review only on the automobile manufacturers' argument that Fernandez lacks standing to bring a class action against them.

3

. At oral argument, Fernandez's counsel conceded that Honda had never been served with the complaint.

4

. See Fed.R.Civ.P. 23(a)-(d).

5

. Although Fernandez made this argument in her appellate briefs, the court of appeals did not address it.