rigorous standard (Arizona) · Go Syfert
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rigorous standard in Arizona

10 Arizona opinions name it 2 courts 1981–2026 5 in the last five years

The cases below were cited by Arizona courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (13)

CaseFollowedCited
Amchem Products, Inc. v. Windsorgreen
scotus · 1997 · cited in 2 Arizona opinions naming this issue, 2026–2026
2 sentences

2026The superior court, however, recognized the more rigorous standard discussed in Wal-Mart and purported to apply it. 4 ROBERTS, et al., v. STATE Decision of the Court class-wide resolution, and the remaining inquiries necessary to resolve Plaintiffs’ claims require individual proof. ¶10 The “predominance inquiry tests whether proposed classes are sufficiently cohesive to warrant adjudication by representation.” Amchem Prods., Inc. v. Windsor, 521 U.S. 591, 623 (1997).

2026Amchem Prods., Inc. v. Windsor, 521 U.S. 591, 614 (1997).2 For its part, Rule 23(b)(3) permits class certification when aggregate adjudication is “convenient and desirable.” Id. at 615 . ¶13 Class certification “is proper only if the trial court is satisfied, after a rigorous analysis, that the prerequisites of Rule 23(a) have been satisfied.” Ferrara, 245 Ariz. at 380 ¶ 6 (citation omitted).

22
Comcast Corp. v. Behrendgreen
scotus · 2013 · cited in 2 Arizona opinions naming this issue, 2018–2021
2 sentences

2021No. 1, 18 Ariz. App. 283, 286 (1972). “[C]ertification is proper only if ‘the trial court is satisfied, after a rigorous analysis, that [Federal] [Rule 23’s] prerequisites . . . have been satisfied.’” Comcast Corp. v. Behrend, 569 U.S. 27, 33 (2013) (citation omitted); see ESI Ergonomic Sols., LLC v. United Artists Theatre Cir., Inc., 203 Ariz. 94, 98 , ¶ 11 n.2 (App. 2002) (“Because Rule 23 is identical to Rule 23 of the Federal Rules of Civil Procedure, we view federal cases construing the federal rule as authoritative.”). ¶9 “An order that certifies a class action must: . . . (iii) set fort

2018In addressing Rule 23 of the Federal Rules of Civil Procedure, the United States Supreme Court has emphasized that "it may be necessary for the court to probe behind the pleadings before coming to rest on the certification question, and that certification is proper only if the trial court is satisfied, after a rigorous analysis, that the prerequisites of Rule 23(a) have been satisfied." Comcast Corp. v. Behrend , 569 U.S. 27 , 33, 133 S.Ct. 1426 , 185 L.Ed.2d 515 (2013) (quoting Wal-Mart Stores, Inc. v. Dukes , 564 U.S. 338 , 350-51, 131 S.Ct. 2541 , 180 L.Ed.2d 374 (2011) ). 2 "The issue of w

12
Tyson Foods, Inc. v. Bouaphakeogreen
scotus · 2016 · cited in 1 Arizona opinions naming this issue, 2026–2026
1 sentence

2026To decide this question, a court must consider whether common questions—those where “the same evidence will suffice for each member to make a prima facie showing [or] the issue is susceptible to generalized, class-wide proof”—are more prevalent or important than individual questions—those where “members of a proposed class will need to present evidence that varies from member to member.” Tyson Foods v. Bouaphakeo, 577 U.S. 442, 453 (2016) (internal citation omitted). ¶11 The predominance inquiry “begins, of course, with the elements of the underlying cause of action.” Erica P. John Fund, Inc.

11
Neale v. Volvo Cars of North America, LLCgreen
ca3 · 2015 · cited in 1 Arizona opinions naming this issue, 2026–2026
1 sentence

2026To decide this question, a court must consider whether common questions—those where “the same evidence will suffice for each member to make a prima facie showing [or] the issue is susceptible to generalized, class-wide proof”—are more prevalent or important than individual questions—those where “members of a proposed class will need to present evidence that varies from member to member.” Tyson Foods v. Bouaphakeo, 577 U.S. 442, 453 (2016) (internal citation omitted). ¶11 The predominance inquiry “begins, of course, with the elements of the underlying cause of action.” Erica P. John Fund, Inc.

11
cluster 1741green
· · cited in 1 Arizona opinions naming this issue, 2024–2024
1 sentence

2024See id.

11
Carpinteiro v. TUCSON SCH. DIST. NO 1 OF PIMA CTY.green
arizctapp · 1972 · cited in 1 Arizona opinions naming this issue, 2021–2021
1 sentence

2021No. 1, 18 Ariz. App. 283, 286 (1972). “[C]ertification is proper only if ‘the trial court is satisfied, after a rigorous analysis, that [Federal] [Rule 23’s] prerequisites . . . have been satisfied.’” Comcast Corp. v. Behrend, 569 U.S. 27, 33 (2013) (citation omitted); see ESI Ergonomic Sols., LLC v. United Artists Theatre Cir., Inc., 203 Ariz. 94, 98 , ¶ 11 n.2 (App. 2002) (“Because Rule 23 is identical to Rule 23 of the Federal Rules of Civil Procedure, we view federal cases construing the federal rule as authoritative.”). ¶9 “An order that certifies a class action must: . . . (iii) set fort

11
ESI Ergonomic Solutions, LLC v. United Artists Theatre Circuit, Inc.green
arizctapp · 2002 · cited in 1 Arizona opinions naming this issue, 2021–2021
1 sentence

2021No. 1, 18 Ariz. App. 283, 286 (1972). “[C]ertification is proper only if ‘the trial court is satisfied, after a rigorous analysis, that [Federal] [Rule 23’s] prerequisites . . . have been satisfied.’” Comcast Corp. v. Behrend, 569 U.S. 27, 33 (2013) (citation omitted); see ESI Ergonomic Sols., LLC v. United Artists Theatre Cir., Inc., 203 Ariz. 94, 98 , ¶ 11 n.2 (App. 2002) (“Because Rule 23 is identical to Rule 23 of the Federal Rules of Civil Procedure, we view federal cases construing the federal rule as authoritative.”). ¶9 “An order that certifies a class action must: . . . (iii) set fort

11
Linthicum v. Nationwide Life Insurancegreen
ariz · 1986 · cited in 1 Arizona opinions naming this issue, 2008–2008
2 sentences

2008See, e.g., Crum, 190 Ariz. at 515, 950 P.2d at 174; see also Linthicum, 150 Ariz. at 332 , 723 P.2d at 681 (distinguishing between bad faith and the more rigorous standard of acting with an “evil mind”). ¶ 38 We refuse to apply punitive damages requirements to treble damages.

2008See, e.g., Crum, 190 Ariz. at 515, 950 P.2d at 174; see also Linthicum, 150 Ariz. at 332 , 723 P.2d at 681 (distinguishing between bad faith and the more rigorous standard of acting with an “evil mind”). ¶ 38 We refuse to apply punitive damages requirements to treble damages.

11
Staples v. United Statesgreen
scotus · 1994 · cited in 1 Arizona opinions naming this issue, 1998–1998
2 sentences

1998See Staples, 511 U.S. at 607 -08 n. 3, 114 S.Ct. at 1798 n. 3 (“True strict liability might suggest that the defendant need not know even that he was dealing with a dangerous item.”). ¶31 Some federal courts, after relieving the government of the more rigorous requirement of proving a defendant’s knowledge of the specific offending characteristics of certain classes of suspect weapons, have identified a less rigorous scienter requirement.

1998See Staples, 511 U.S. at 607 -08 n. 3, 114 S.Ct. at 1798 n. 3 (“True strict liability might suggest that the defendant need not know even that he was dealing with a dangerous item.”). ¶31 Some federal courts, after relieving the government of the more rigorous requirement of proving a defendant’s knowledge of the specific offending characteristics of certain classes of suspect weapons, have identified a less rigorous scienter requirement.

11
Wilkes v. Gomezgreen
ca8 · 1994 · cited in 1 Arizona opinions naming this issue, 1998–1998
1 sentence

1998See United States v. Farrell, 69 F.3d 891, 894 (8th Cir.1995) (in prosecution for unlawful possession and transfer of statutory firearm under Firearms Owner’s Protection Act, government need only prove defendant knowingly possessed a “quasi-suspect” weapon (machine gun) and observed its characteristics), cer t. denied 516 U.S. 1181 , 116 S.Ct. 1283 , 134 L.Ed.2d 228 (1996); Barr, 32 F.3d at 1324 (in prosecution for unlawful possession of statutory firearm under National Firearms Act, the government need only prove the defendant knowingly possessed a “quasi-suspect” weapon (sawed-off shotgun) a

11
United States v. Anthony Farrellgreen
ca8 · 1995 · cited in 1 Arizona opinions naming this issue, 1998–1998
1 sentence

1998See United States v. Farrell, 69 F.3d 891, 894 (8th Cir.1995) (in prosecution for unlawful possession and transfer of statutory firearm under Firearms Owner’s Protection Act, government need only prove defendant knowingly possessed a “quasi-suspect” weapon (machine gun) and observed its characteristics), cer t. denied 516 U.S. 1181 , 116 S.Ct. 1283 , 134 L.Ed.2d 228 (1996); Barr, 32 F.3d at 1324 (in prosecution for unlawful possession of statutory firearm under National Firearms Act, the government need only prove the defendant knowingly possessed a “quasi-suspect” weapon (sawed-off shotgun) a

11
Waters v. United Statesgreen
scotus · 1996 · cited in 1 Arizona opinions naming this issue, 1998–1998
1 sentence

1998See United States v. Farrell, 69 F.3d 891, 894 (8th Cir.1995) (in prosecution for unlawful possession and transfer of statutory firearm under Firearms Owner’s Protection Act, government need only prove defendant knowingly possessed a “quasi-suspect” weapon (machine gun) and observed its characteristics), cer t. denied 516 U.S. 1181 , 116 S.Ct. 1283 , 134 L.Ed.2d 228 (1996); Barr, 32 F.3d at 1324 (in prosecution for unlawful possession of statutory firearm under National Firearms Act, the government need only prove the defendant knowingly possessed a “quasi-suspect” weapon (sawed-off shotgun) a

11
Marutz v. United Statesgreen
scotus · 1996 · cited in 1 Arizona opinions naming this issue, 1998–1998
1 sentence

1998See United States v. Farrell, 69 F.3d 891, 894 (8th Cir.1995) (in prosecution for unlawful possession and transfer of statutory firearm under Firearms Owner’s Protection Act, government need only prove defendant knowingly possessed a “quasi-suspect” weapon (machine gun) and observed its characteristics), cer t. denied 516 U.S. 1181 , 116 S.Ct. 1283 , 134 L.Ed.2d 228 (1996); Barr, 32 F.3d at 1324 (in prosecution for unlawful possession of statutory firearm under National Firearms Act, the government need only prove the defendant knowingly possessed a “quasi-suspect” weapon (sawed-off shotgun) a

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Arizona. Read the followed side critically anyway.

Also cited on this issue (5)

CaseCitedYears
Erica P. John Fund, Inc. v. Halliburton Co. green
scotus · 2011
1 sentence

2026To decide this question, a court must consider whether common questions—those where “the same evidence will suffice for each member to make a prima facie showing [or] the issue is susceptible to generalized, class-wide proof”—are more prevalent or important than individual questions—those where “members of a proposed class will need to present evidence that varies from member to member.” Tyson Foods v. Bouaphakeo, 577 U.S. 442, 453 (2016) (internal citation omitted). ¶11 The predominance inquiry “begins, of course, with the elements of the underlying cause of action.” Erica P. John Fund, Inc.

12026–2026
Downs v. Scheffler green
arizctapp · 2003
1 sentence

2025A.R.S. § 25-411(L) and Summary Dismissal. ¶14 Mother contends the superior court erred by: (1) evaluating whether there was a "substantial" change in circumstances, arguing that this is a more rigorous standard than the "material" standard set forth for A.R.S. § 25-411(L) in Backstrand; and (2) summarily dismissing the petition after she met the prerequisites for an evidentiary hearing as discussed in Downs v. Scheffler, 206 Ariz. 496 (App. 2003). ¶15 Mother's first argument is unpersuasive.

12025–2025
Wal-Mart Stores, Inc. v. Dukes green
scotus · 2011
2 sentences

2018In addressing Rule 23 of the Federal Rules of Civil Procedure, the United States Supreme Court has emphasized that "it may be necessary for the court to probe behind the pleadings before coming to rest on the certification question, and that certification is proper only if the trial court is satisfied, after a rigorous analysis, that the prerequisites of Rule 23(a) have been satisfied." Comcast Corp. v. Behrend , 569 U.S. 27 , 33, 133 S.Ct. 1426 , 185 L.Ed.2d 515 (2013) (quoting Wal-Mart Stores, Inc. v. Dukes , 564 U.S. 338 , 350-51, 131 S.Ct. 2541 , 180 L.Ed.2d 374 (2011) ). 2 "The issue of w

2018In addressing Rule 23 of the Federal Rules of Civil Procedure, the United States Supreme Court has emphasized that "it may be necessary for the court to probe behind the pleadings before coming to rest on the certification question, and that certification is proper only if the trial court is satisfied, after a rigorous analysis, that the prerequisites of Rule 23(a) have been satisfied." Comcast Corp. v. Behrend , 569 U.S. 27 , 33, 133 S.Ct. 1426 , 185 L.Ed.2d 515 (2013) (quoting Wal-Mart Stores, Inc. v. Dukes , 564 U.S. 338 , 350-51, 131 S.Ct. 2541 , 180 L.Ed.2d 374 (2011) ). 2 "The issue of w

12018–2018
Carey v. Population Services International green
scotus · 1977
2 sentences

1990Carey, 431 U.S. at 693 n. 15, 97 S.Ct. at 2020 n. 15, 52 L.Ed.2d at 690 n. 15.

1990Carey, 431 U.S. at 693 n. 15, 97 S.Ct. at 2020 n. 15, 52 L.Ed.2d at 690 n. 15.

11990–1990
Spinelli v. United States red
scotus · 1969
2 sentences

1981Spinelli v. United States, 393 U.S. 410 , 89 S.Ct. 584 , 21 L.Ed.2d 637 (1969).

1981Spinelli v. United States, 393 U.S. 410 , 89 S.Ct. 584 , 21 L.Ed.2d 637 (1969).

11981–1981

Statutes the citing opinions construe

AZ § Ariz. Rev. Stat. § 12-1873 (4)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TX 182 (1915–2026) IN 129 (1989–2025) CA 99 (1923–2026) OH 96 (1991–2025) LA 80 (1911–2022) NY 67 (1899–2026) IL 64 (1941–2025) OR 62 (1928–2026) FL 46 (1974–2025) NJ 39 (1976–2025) AL 39 (1917–2026) ID 34 (1972–2023) MA 32 (1973–2026) WA 30 (1944–2023) NC 28 (1913–2021) PA 28 (1925–2026) MD 23 (1925–2026) KS 22 (1879–2024) NV 22 (1996–2024) DC 21 (1952–2023) AR 20 (1893–2024) GA 20 (1983–2025) MI 19 (1919–2025) CT 19 (1976–2025) ND 18 (1982–2002) WI 18 (1923–2025) RI 17 (1983–2015) TN 17 (1931–2025) NM 16 (1978–2021) MN 15 (1972–2018) VT 14 (1980–2026) UT 14 (1933–2016) WY 14 (1893–2025) MO 13 (1958–2025) ME 13 (1972–2020) KY 13 (1946–2025) WV 11 (1909–2022) CO 11 (1995–2022) IA 11 (1915–2026) AZ 10 (1981–2026) VA 10 (1906–2020) AK 6 (1972–2011) DE 6 (1989–2026) NH 5 (1990–2018) MT 4 (1900–2016) OK 4 (2007–2023) MS 3 (1998–2018) SD 3 (2003–2013) HI 3 (1981–2009) NE 2 (1897–2004) SC 2 (1989–2018)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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