probable cause standard in Arizona

2025Although the state is correct that the rules are silent as to the timing of a probable cause hearing, Navarro-Figueroa cites Chronis as guidance for when that hearing must occur. ¶7 In Chronis, our supreme court explained the meaning of a “challenge [to] the legal sufficiency” in the context of Rule 13.5(c). 220 Ariz. 559, ¶¶ 5-10 (quoting Ariz. R.

2025But under Rule 5.4(c), the evidence presented at a probable cause hearing “may include hearsay” from an expert’s written report, from documentary evidence without foundation, and from a witness’s testimony about another person’s declarations.2 Thus, we are unpersuaded that such a hearing would resemble a trial or be particularly burdensome for the state. 3 See Chronis, 220 Ariz. 559, ¶ 19 (“Given the focused nature of probable cause hearings and the prosecution’s wide ability to offer different forms of evidence, we are not persuaded by the State’s argument that allowing probable cause determi

2022The probable cause standard “requires only a probability or substantial chance of criminal activity, not an actual showing of such activity.” State v. Sisco, 239 Ariz. 532 , 536 ¶ 15 (2016) (quoting Illinois v. Gates, 462 U.S. 213 , 243 n.13 (1983)).

2015See State v. Richcreek, 187 Ariz. 501, 504 , 930 P.2d 1304, 1307 (1997) (disapproving prior jurisprudence which had stated that police officers who confront “ ‘strange or unusual activities ... should satisfy [themselves] as to the innocence of the activity by all reasonable, lawful means’ ”), quoting State v. Jarzab, 123 Ariz. 308, 311 , 599 P.2d 761, 764 (1979). ¶ 12 Although the probable-cause standard might occasionally disturb the innocent, Gates, 462 U.S. at 243 n. 13, 103 S.Ct. 2317 , it is not designed to do so as a matter of course, turning a blind eye to lawful activities and seeing

2022See, e.g., Brinegar v. United States, 338 U.S. 160, 175 (1949) (standard of proof necessary to establish probable cause “‘means less than evidence which would justify’ . . . conviction” (quoting Locke v. United States, 11 U.S. 339, 344 (1813))).

2015Our state has long recognized that the standard is not met when “slight reflection” would suggest to an ordinarily cautious and prudent person that those suspected of an offense “might have been peaceable and respectable people.” Wiley v. State, 19 Ariz. 346, 354 , 170 P. 869, 873 (1918); see, e.g., Ex parte Beaver, 23 Ariz. 24, 26 , 201 P. 94, 95 (1921) (finding no probable cause for arrest when noncriminal explanations for facts were reasonable assumptions, and evidence failed to show any crime had been committed). ¶ 13 When mistakes are made, “ ‘the mistakes must be those of reasonable [peo

2004Florida v. Royer, 460 U.S. 491, 500 , 103 S.Ct. 1319, 1325-26 , 75 L.Ed.2d 229, 238 (“An investigative detention must be temporary and last no longer than is necessary to effectuate the purpose of the stop [and] ... the investigative methods employed should be the least intrusive means reasonably available to dispel the officer’s suspicion in a short period of time.”); State v. Winegar, 147 Ariz. 440, 447 , 711 P.2d 579, 586 (1985) (“Terry stops are tolerated as an exception to the probable cause requirement of the Fourth Amendment because they are brief and as narrowly circumscribed as possib

2004Florida v. Royer, 460 U.S. 491, 500 , 103 S.Ct. 1319, 1325-26 , 75 L.Ed.2d 229, 238 (“An investigative detention must be temporary and last no longer than is necessary to effectuate the purpose of the stop [and] ... the investigative methods employed should be the least intrusive means reasonably available to dispel the officer’s suspicion in a short period of time.”); State v. Winegar, 147 Ariz. 440, 447 , 711 P.2d 579, 586 (1985) (“Terry stops are tolerated as an exception to the probable cause requirement of the Fourth Amendment because they are brief and as narrowly circumscribed as possib

2015Our state has long recognized that the standard is not met when “slight reflection” would suggest to an ordinarily cautious and prudent person that those suspected of an offense “might have been peaceable and respectable people.” Wiley v. State, 19 Ariz. 346, 354 , 170 P. 869, 873 (1918); see, e.g., Ex parte Beaver, 23 Ariz. 24, 26 , 201 P. 94, 95 (1921) (finding no probable cause for arrest when noncriminal explanations for facts were reasonable assumptions, and evidence failed to show any crime had been committed). ¶ 13 When mistakes are made, “ ‘the mistakes must be those of reasonable [peo

2015Our state has long recognized that the standard is not met when “slight reflection” would suggest to an ordinarily cautious and prudent person that those suspected of an offense “might have been peaceable and respectable people.” Wiley v. State, 19 Ariz. 346, 354 , 170 P. 869, 873 (1918); see, e.g., Ex parte Beaver, 23 Ariz. 24, 26 , 201 P. 94, 95 (1921) (finding no probable cause for arrest when noncriminal explanations for facts were reasonable assumptions, and evidence failed to show any crime had been committed). ¶ 13 When mistakes are made, “ ‘the mistakes must be those of reasonable [peo

2015Our state has long recognized that the standard is not met when “slight reflection” would suggest to an ordinarily cautious and prudent person that those suspected of an offense “might have been peaceable and respectable people.” Wiley v. State, 19 Ariz. 346, 354 , 170 P. 869, 873 (1918); see, e.g., Ex parte Beaver, 23 Ariz. 24, 26 , 201 P. 94, 95 (1921) (finding no probable cause for arrest when noncriminal explanations for facts were reasonable assumptions, and evidence failed to show any crime had been committed). ¶ 13 When mistakes are made, “ ‘the mistakes must be those of reasonable [peo

2015Our state has long recognized that the standard is not met when “slight reflection” would suggest to an ordinarily cautious and prudent person that those suspected of an offense “might have been peaceable and respectable people.” Wiley v. State, 19 Ariz. 346, 354 , 170 P. 869, 873 (1918); see, e.g., Ex parte Beaver, 23 Ariz. 24, 26 , 201 P. 94, 95 (1921) (finding no probable cause for arrest when noncriminal explanations for facts were reasonable assumptions, and evidence failed to show any crime had been committed). ¶ 13 When mistakes are made, “ ‘the mistakes must be those of reasonable [peo

2015See State v. Caraveo, 222 Ariz. 228, ¶¶ 8, 23 , 213 P.3d 377, 379, 382 (App. 2009) (remanding for determination whether search permissible based on different legal argument made below but not addressed by trial court); State v. Branham, 191 Ariz. 94, 98 , 952 P.2d 332, 336 (App. 1997) (remanding for reconsideration where “trial court’s basis for denying the motion to suppress was incorrect” and it had not ruled on question whether consent justified search).

2015See State v. Caraveo, 222 Ariz. 228, ¶¶ 8, 23 , 213 P.3d 377, 379, 382 (App. 2009) (remanding for determination whether search permissible based on different legal argument made below but not addressed by trial court); State v. Branham, 191 Ariz. 94, 98 , 952 P.2d 332, 336 (App. 1997) (remanding for reconsideration where “trial court’s basis for denying the motion to suppress was incorrect” and it had not ruled on question whether consent justified search).

2015See Chalpin v. Snyder, 220 Ariz. 413, 419, ¶ 21 , 207 P.3d 666, 672 (App. 2008).

2015See Chalpin v. Snyder, 220 Ariz. 413, 419, ¶ 21 , 207 P.3d 666, 672 (App. 2008).

2015See State v. Caraveo, 222 Ariz. 228, ¶¶ 8, 23 , 213 P.3d 377, 379, 382 (App. 2009) (remanding for determination whether search permissible based on different legal argument made below but not addressed by trial court); State v. Branham, 191 Ariz. 94, 98 , 952 P.2d 332, 336 (App. 1997) (remanding for reconsideration where “trial court’s basis for denying the motion to suppress was incorrect” and it had not ruled on question whether consent justified search).

2015See State v. Caraveo, 222 Ariz. 228, ¶¶ 8, 23 , 213 P.3d 377, 379, 382 (App. 2009) (remanding for determination whether search permissible based on different legal argument made below but not addressed by trial court); State v. Branham, 191 Ariz. 94, 98 , 952 P.2d 332, 336 (App. 1997) (remanding for reconsideration where “trial court’s basis for denying the motion to suppress was incorrect” and it had not ruled on question whether consent justified search).

2015Our state has long recognized that the standard is not met when “slight reflection” would suggest to an ordinarily cautious and prudent person that those suspected of an offense “might have been peaceable and respectable people.” Wiley v. State, 19 Ariz. 346, 354 , 170 P. 869, 873 (1918); see, e.g., Ex parte Beaver, 23 Ariz. 24, 26 , 201 P. 94, 95 (1921) (finding no probable cause for arrest when noncriminal explanations for facts were reasonable assumptions, and evidence failed to show any crime had been committed). ¶ 13 When mistakes are made, “ ‘the mistakes must be those of reasonable [peo

2015Our state has long recognized that the standard is not met when “slight reflection” would suggest to an ordinarily cautious and prudent person that those suspected of an offense “might have been peaceable and respectable people.” Wiley v. State, 19 Ariz. 346, 354 , 170 P. 869, 873 (1918); see, e.g., Ex parte Beaver, 23 Ariz. 24, 26 , 201 P. 94, 95 (1921) (finding no probable cause for arrest when noncriminal explanations for facts were reasonable assumptions, and evidence failed to show any crime had been committed). ¶ 13 When mistakes are made, “ ‘the mistakes must be those of reasonable [peo

2015See State v. Richcreek, 187 Ariz. 501, 504 , 930 P.2d 1304, 1307 (1997) (disapproving prior jurisprudence which had stated that police officers who confront “ ‘strange or unusual activities ... should satisfy [themselves] as to the innocence of the activity by all reasonable, lawful means’ ”), quoting State v. Jarzab, 123 Ariz. 308, 311 , 599 P.2d 761, 764 (1979). ¶ 12 Although the probable-cause standard might occasionally disturb the innocent, Gates, 462 U.S. at 243 n. 13, 103 S.Ct. 2317 , it is not designed to do so as a matter of course, turning a blind eye to lawful activities and seeing

2015See State v. Richcreek, 187 Ariz. 501, 504 , 930 P.2d 1304, 1307 (1997) (disapproving prior jurisprudence which had stated that police officers who confront “ ‘strange or unusual activities ... should satisfy [themselves] as to the innocence of the activity by all reasonable, lawful means’ ”), quoting State v. Jarzab, 123 Ariz. 308, 311 , 599 P.2d 761, 764 (1979). ¶ 12 Although the probable-cause standard might occasionally disturb the innocent, Gates, 462 U.S. at 243 n. 13, 103 S.Ct. 2317 , it is not designed to do so as a matter of course, turning a blind eye to lawful activities and seeing

2015See State v. Richcreek, 187 Ariz. 501, 504 , 930 P.2d 1304, 1307 (1997) (disapproving prior jurisprudence which had stated that police officers who confront “ ‘strange or unusual activities ... should satisfy [themselves] as to the innocence of the activity by all reasonable, lawful means’ ”), quoting State v. Jarzab, 123 Ariz. 308, 311 , 599 P.2d 761, 764 (1979). ¶ 12 Although the probable-cause standard might occasionally disturb the innocent, Gates, 462 U.S. at 243 n. 13, 103 S.Ct. 2317 , it is not designed to do so as a matter of course, turning a blind eye to lawful activities and seeing

2015See State v. Richcreek, 187 Ariz. 501, 504 , 930 P.2d 1304, 1307 (1997) (disapproving prior jurisprudence which had stated that police officers who confront “ ‘strange or unusual activities ... should satisfy [themselves] as to the innocence of the activity by all reasonable, lawful means’ ”), quoting State v. Jarzab, 123 Ariz. 308, 311 , 599 P.2d 761, 764 (1979). ¶ 12 Although the probable-cause standard might occasionally disturb the innocent, Gates, 462 U.S. at 243 n. 13, 103 S.Ct. 2317 , it is not designed to do so as a matter of course, turning a blind eye to lawful activities and seeing

2015Co. v. Ariz. Corp. Comm’n, 160 Ariz. 350, 354 , 773 P.2d 455, 459 (1989) (“jurisprudential considerations require us to decide the case on the narrowest grounds possible”). ¶74 In sum, because under the facts and circumstances of this case any reasonable person would conclude there was a “fair probability that contraband or evidence of a crime w[ould] be found” in the storage unit, Gates, 462 U.S. at 238 , and because the investigating officers executed the search in good-faith reliance on a neutral magistrate’s warrant, see Leon, 468 U.S. at 920 , it is unnecessary to interpret Arizona’s Medi

2015Co. v. Ariz. Corp. Comm’n, 160 Ariz. 350, 354 , 773 P.2d 455, 459 (1989) (“jurisprudential considerations require us to decide the case on the narrowest grounds possible”). ¶74 In sum, because under the facts and circumstances of this case any reasonable person would conclude there was a “fair probability that contraband or evidence of a crime w[ould] be found” in the storage unit, Gates, 462 U.S. at 238 , and because the investigating officers executed the search in good-faith reliance on a neutral magistrate’s warrant, see Leon, 468 U.S. at 920 , it is unnecessary to interpret Arizona’s Medi

2004Route, 104 F.3d at 62 (emphasis added ), quoting United States v. Woods, 560 F.2d 660, 665 (5th Ci r. 1977 ), quoting United States v. Cravero, 545 F.2d 406, 421 (5th Cir. 197 6); accord Magluta, 44 F.3d at 1 535; see also Green, 78 S.W .3d at 612; Valdez, 172 F.3d at 1224-25, 1228 (distinguishing reason-to- 9 believe standard from probable-cause standard but finding that officers had possessed reasonable belief beca use they had concluded suspect “would likely be pres ent inside”). ¶15 Thus, the case authority does not uniformly equate the reason-to-believe standard with the probable-cause st

2004Route, 104 F.3d at 62 (emphasis added), quoting United States v. Woods, 560 F.2d 660, 665 (5th Cir.1977), quoting United States v. Cravero, 545 F.2d 406, 421 (5th Cir.1976); accord Magluta, 44 F.3d at 1535; see also Green, 78 S.W.3d at 612 ; Valdez, 172 F.3d at 1224-25, 1228 (distinguishing reason-to-believe standard from probable-cause standard but finding that officers had possessed reasonable belief because they had concluded suspect “would likely be present inside”). ¶ 15 Thus, the ease authority does not uniformly equate the reason-to-believe standard with the probable-cause standard.

2004Route, 104 F.3d at 62 (emphasis added ), quoting United States v. Woods, 560 F.2d 660, 665 (5th Ci r. 1977 ), quoting United States v. Cravero, 545 F.2d 406, 421 (5th Cir. 197 6); accord Magluta, 44 F.3d at 1 535; see also Green, 78 S.W .3d at 612; Valdez, 172 F.3d at 1224-25, 1228 (distinguishing reason-to- 9 believe standard from probable-cause standard but finding that officers had possessed reasonable belief beca use they had concluded suspect “would likely be pres ent inside”). ¶15 Thus, the case authority does not uniformly equate the reason-to-believe standard with the probable-cause st

2004Route, 104 F.3d at 62 (emphasis added), quoting United States v. Woods, 560 F.2d 660, 665 (5th Cir.1977), quoting United States v. Cravero, 545 F.2d 406, 421 (5th Cir.1976); accord Magluta, 44 F.3d at 1535; see also Green, 78 S.W.3d at 612 ; Valdez, 172 F.3d at 1224-25, 1228 (distinguishing reason-to-believe standard from probable-cause standard but finding that officers had possessed reasonable belief because they had concluded suspect “would likely be present inside”). ¶ 15 Thus, the ease authority does not uniformly equate the reason-to-believe standard with the probable-cause standard.

2004Route, 104 F.3d at 62 (emphasis added ), quoting United States v. Woods, 560 F.2d 660, 665 (5th Ci r. 1977 ), quoting United States v. Cravero, 545 F.2d 406, 421 (5th Cir. 197 6); accord Magluta, 44 F.3d at 1 535; see also Green, 78 S.W .3d at 612; Valdez, 172 F.3d at 1224-25, 1228 (distinguishing reason-to- 9 believe standard from probable-cause standard but finding that officers had possessed reasonable belief beca use they had concluded suspect “would likely be pres ent inside”). ¶15 Thus, the case authority does not uniformly equate the reason-to-believe standard with the probable-cause st

2004Route, 104 F.3d at 62 (emphasis added), quoting United States v. Woods, 560 F.2d 660, 665 (5th Cir.1977), quoting United States v. Cravero, 545 F.2d 406, 421 (5th Cir.1976); accord Magluta, 44 F.3d at 1535; see also Green, 78 S.W.3d at 612 ; Valdez, 172 F.3d at 1224-25, 1228 (distinguishing reason-to-believe standard from probable-cause standard but finding that officers had possessed reasonable belief because they had concluded suspect “would likely be present inside”). ¶ 15 Thus, the ease authority does not uniformly equate the reason-to-believe standard with the probable-cause standard.

2004Route, 104 F.3d at 62 (emphasis added ), quoting United States v. Woods, 560 F.2d 660, 665 (5th Ci r. 1977 ), quoting United States v. Cravero, 545 F.2d 406, 421 (5th Cir. 197 6); accord Magluta, 44 F.3d at 1 535; see also Green, 78 S.W .3d at 612; Valdez, 172 F.3d at 1224-25, 1228 (distinguishing reason-to- 9 believe standard from probable-cause standard but finding that officers had possessed reasonable belief beca use they had concluded suspect “would likely be pres ent inside”). ¶15 Thus, the case authority does not uniformly equate the reason-to-believe standard with the probable-cause st

2004Route, 104 F.3d at 62 (emphasis added), quoting United States v. Woods, 560 F.2d 660, 665 (5th Cir.1977), quoting United States v. Cravero, 545 F.2d 406, 421 (5th Cir.1976); accord Magluta, 44 F.3d at 1535; see also Green, 78 S.W.3d at 612 ; Valdez, 172 F.3d at 1224-25, 1228 (distinguishing reason-to-believe standard from probable-cause standard but finding that officers had possessed reasonable belief because they had concluded suspect “would likely be present inside”). ¶ 15 Thus, the ease authority does not uniformly equate the reason-to-believe standard with the probable-cause standard.

2004Route, 104 F.3d at 62 (emphasis added ), quoting United States v. Woods, 560 F.2d 660, 665 (5th Ci r. 1977 ), quoting United States v. Cravero, 545 F.2d 406, 421 (5th Cir. 197 6); accord Magluta, 44 F.3d at 1 535; see also Green, 78 S.W .3d at 612; Valdez, 172 F.3d at 1224-25, 1228 (distinguishing reason-to- 9 believe standard from probable-cause standard but finding that officers had possessed reasonable belief beca use they had concluded suspect “would likely be pres ent inside”). ¶15 Thus, the case authority does not uniformly equate the reason-to-believe standard with the probable-cause st

2004Route, 104 F.3d at 62 (emphasis added), quoting United States v. Woods, 560 F.2d 660, 665 (5th Cir.1977), quoting United States v. Cravero, 545 F.2d 406, 421 (5th Cir.1976); accord Magluta, 44 F.3d at 1535; see also Green, 78 S.W.3d at 612 ; Valdez, 172 F.3d at 1224-25, 1228 (distinguishing reason-to-believe standard from probable-cause standard but finding that officers had possessed reasonable belief because they had concluded suspect “would likely be present inside”). ¶ 15 Thus, the ease authority does not uniformly equate the reason-to-believe standard with the probable-cause standard.

2004Under the common law “discovery rule,” a cause of action accrues for purposes of A.R.S. § 12-542, and the limitation period then begins, when “the plaintiff knows or with reasonable diligence should know the facts underlying the cause.” Doe v. Roe, 191 Ariz. 313, ¶ 29 , 955 P.2d 951, 960 (1998); see also Walk v. Ring, 202 Ariz. 310, ¶22 , 44 P.3d 990, 996 (2002) (for limitation period to commence, “it is not enough that a plaintiff comprehends a *what’; there must also be reason to connect the “what’ to a particular Vho’ in such a way that a reasonable person would be on notice to investigate

2004Under the common law “discovery rule,” a cause of action accrues for purposes of A.R.S. § 12-542, and the limitation period then begins, when “the plaintiff knows or with reasonable diligence should know the facts underlying the cause.” Doe v. Roe, 191 Ariz. 313, ¶ 29 , 955 P.2d 951, 960 (1998); see also Walk v. Ring, 202 Ariz. 310, ¶22 , 44 P.3d 990, 996 (2002) (for limitation period to commence, “it is not enough that a plaintiff comprehends a *what’; there must also be reason to connect the “what’ to a particular Vho’ in such a way that a reasonable person would be on notice to investigate

2004Under the common law “discovery rule,” a cause of action accrues for purposes of A.R.S. § 12-542, and the limitation period then begins, when “the plaintiff knows or with reasonable diligence should know the facts underlying the cause.” Doe v. Roe, 191 Ariz. 313, ¶ 29 , 955 P.2d 951, 960 (1998); see also Walk v. Ring, 202 Ariz. 310, ¶22 , 44 P.3d 990, 996 (2002) (for limitation period to commence, “it is not enough that a plaintiff comprehends a *what’; there must also be reason to connect the “what’ to a particular Vho’ in such a way that a reasonable person would be on notice to investigate

2004Under the common law “discovery rule,” a cause of action accrues for purposes of A.R.S. § 12-542, and the limitation period then begins, when “the plaintiff knows or with reasonable diligence should know the facts underlying the cause.” Doe v. Roe, 191 Ariz. 313, ¶ 29 , 955 P.2d 951, 960 (1998); see also Walk v. Ring, 202 Ariz. 310, ¶22 , 44 P.3d 990, 996 (2002) (for limitation period to commence, “it is not enough that a plaintiff comprehends a *what’; there must also be reason to connect the “what’ to a particular Vho’ in such a way that a reasonable person would be on notice to investigate

2002But assuming the requisite showing of "reasonable grounds” under § 28-1321(K)(l) is equivalent to a probable cause standard, see Pearson v. Motor Vehicle Division, 181 Ariz. 235, 237 , 889 P.2d 28, 30 (App.1995); Smith v. Arizona Dep’t of Transp., 146 Ariz. 430, 432 , 706 P.2d 756, 758 (App. 1985), MVD made such a showing here.

2002But assuming the requisite showing of "reasonable grounds” under § 28-1321(K)(l) is equivalent to a probable cause standard, see Pearson v. Motor Vehicle Division, 181 Ariz. 235, 237 , 889 P.2d 28, 30 (App.1995); Smith v. Arizona Dep’t of Transp., 146 Ariz. 430, 432 , 706 P.2d 756, 758 (App. 1985), MVD made such a showing here.

2002But assuming the requisite showing of "reasonable grounds” under § 28-1321(K)(l) is equivalent to a probable cause standard, see Pearson v. Motor Vehicle Division, 181 Ariz. 235, 237 , 889 P.2d 28, 30 (App.1995); Smith v. Arizona Dep’t of Transp., 146 Ariz. 430, 432 , 706 P.2d 756, 758 (App. 1985), MVD made such a showing here.

2002But assuming the requisite showing of "reasonable grounds” under § 28-1321(K)(l) is equivalent to a probable cause standard, see Pearson v. Motor Vehicle Division, 181 Ariz. 235, 237 , 889 P.2d 28, 30 (App.1995); Smith v. Arizona Dep’t of Transp., 146 Ariz. 430, 432 , 706 P.2d 756, 758 (App. 1985), MVD made such a showing here.

2023See Franks, 438 U.S. at 168 (refusing to “denude the probable-cause requirement of all real meaning”). ¶40 In sum, the trial court found that the detective had acted recklessly in providing false and misleading evidence against Scott to secure a search warrant for his buccal swabs.

2014“To allow a magistrate to be misled in such a manner could denude the probable cause requirement of all real meaning.” Id. (citing Franks, 438 U.S. at 168 , 98 S.Ct. 2674 ). ¶ 28 If the defendant then proves, at an evidentiary hearing, perjury or reckless disregard for the truth by a preponderance of the evidence, the false statement must be excised from the affidavit.

2004Under the common law “discovery rule,” a cause of action accrues for purposes of A.R.S. § 12-542, and the limitation period then begins, when “the plaintiff knows or with reasonable diligence should know the facts underlying the cause.” Doe v. Roe, 191 Ariz. 313, ¶ 29 , 955 P.2d 951, 960 (1998); see also Walk v. Ring, 202 Ariz. 310, ¶22 , 44 P.3d 990, 996 (2002) (for limitation period to commence, “it is not enough that a plaintiff comprehends a *what’; there must also be reason to connect the “what’ to a particular Vho’ in such a way that a reasonable person would be on notice to investigate

2004Under the common law “discovery rule,” a cause of action accrues for purposes of A.R.S. § 12-542, and the limitation period then begins, when “the plaintiff knows or with reasonable diligence should know the facts underlying the cause.” Doe v. Roe, 191 Ariz. 313, ¶ 29 , 955 P.2d 951, 960 (1998); see also Walk v. Ring, 202 Ariz. 310, ¶22 , 44 P.3d 990, 996 (2002) (for limitation period to commence, “it is not enough that a plaintiff comprehends a *what’; there must also be reason to connect the “what’ to a particular Vho’ in such a way that a reasonable person would be on notice to investigate

1997See Gerstein v. Pugh, 420 U.S. 103,105-06 , 95 S.Ct. 854, 858-59 , 43 L.Ed.2d 54 (1975) (defendant held without a probable cause hearing); Bell v. Superior Court, 117 Ariz. 551, 552 , 574 P.2d 39, 40 (1977) (juvenile detained pending adjudication); Moss v. Weaver, 525 F.2d 1258, 1259 (5th Cir.1976) (juvenile detained prior to trial).

1997See Gerstein v. Pugh, 420 U.S. 103,105-06 , 95 S.Ct. 854, 858-59 , 43 L.Ed.2d 54 (1975) (defendant held without a probable cause hearing); Bell v. Superior Court, 117 Ariz. 551, 552 , 574 P.2d 39, 40 (1977) (juvenile detained pending adjudication); Moss v. Weaver, 525 F.2d 1258, 1259 (5th Cir.1976) (juvenile detained prior to trial).