tender defense (Arizona) · Go Syfert
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tender defense in Arizona

7 Arizona opinions name it 1 courts 2004–2019 0 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 (7)

CaseFollowedCited
State v. Fellgreen
arizctapp · 2002 · cited in 2 Arizona opinions naming this issue, 2004–2004
2 sentences

2004See State v. Fell, 203 Ariz. 186, ¶¶ 9, 13 , 52 P.3d 218, 220-22 (App.2002). ¶ 35 Second, Bridgestone cites no authority, nor have we found any, for the proposition that a conflict of interest between indem-nitor and indemnitee invalidates the latter’s tender of defense or otherwise renders it “improper.” Restatement § 57(2) states that a conflict of interest might prevent the in-demnitor from “properly ... assum[ing] the defense of the indemnitee.” But that section does not suggest that the tender of defense itself is improper. ¶ 36 Third, as A.P.S. remarked at oral argument, if Bridgestone’s

2004See State v. Fell, 203 Ariz. 186, ¶¶ 9, 13 , 52 P.3d 218, 220-22 (App.2002). ¶ 35 Second, Bridgestone cites no authority, nor have we found any, for the proposition that a conflict of interest between indem-nitor and indemnitee invalidates the latter’s tender of defense or otherwise renders it “improper.” Restatement § 57(2) states that a conflict of interest might prevent the in-demnitor from “properly ... assum[ing] the defense of the indemnitee.” But that section does not suggest that the tender of defense itself is improper. ¶ 36 Third, as A.P.S. remarked at oral argument, if Bridgestone’s

22
Litton Systems, Inc. v. Shaw's Sales & Service, Ltd.green
arizctapp · 1978 · cited in 2 Arizona opinions naming this issue, 2004–2004
2 sentences

2004If Bridgestone ‘“was of the view that it could defend the case better with its own lawyers, it had full opportunity to do so but declined.” ’ Litton Sys., Inc. v. Shaw’s Sales & Serv., Ltd., 119 Ariz. 10, 14 , 579 P.2d 48, 52 (App.1978), quoting Hessler v. Hillwood Mfg.

2004If Bridgestone ‘“was of the view that it could defend the case better with its own lawyers, it had full opportunity to do so but declined.” ’ Litton Sys., Inc. v. Shaw’s Sales & Serv., Ltd., 119 Ariz. 10, 14 , 579 P.2d 48, 52 (App.1978), quoting Hessler v. Hillwood Mfg.

22
Damron v. Sledgegreen
ariz · 1969 · cited in 1 Arizona opinions naming this issue, 2015–2015
2 sentences

2015See Damron v. Sledge, 105 Ariz. 151 , 460 P.2d 997 (1969).

2015See Damron v. Sledge, 105 Ariz. 151 , 460 P.2d 997 (1969).

11
cluster 505498green
· 1988 · cited in 1 Arizona opinions naming this issue, 2004–2004
1 sentence

2004See Restatement § 57(1)(b), (2), cmt. a (indemnitor only precluded from relitigating issues “determined” in underlying action against indemnitee whether or not parties had conflict of interest); see also SCAC Transport (USA) Inc. v. SS Danaos, 845 F.2d 1157 , 1162 (2d Cir. 1988) (preclusive effect of underlying judgment on a properly “vouched-in” indemnitor does not extend to issues not actually determined in the first proceeding); Collins v. Miller & Miller, Ltd., 189 Ariz. 387, 397 , 943 P.2d 747, 757 (App. 1996); Dixon, 509 P.2d at 91 (“Neither the doctrine of collateral estoppel nor the vo

11
Collins v. Miller & Miller, Ltd.green
arizctapp · 1996 · cited in 1 Arizona opinions naming this issue, 2004–2004
2 sentences

2004See Restatement § 57(1)(b), (2), cmt. a (indemnitor only precluded from relitigating issues “determined” in underlying action against indemnitee whether or not parties had conflict of interest); see also SCAC Transport (USA) Inc. v. SS Danaos, 845 F.2d 1157 , 1162 (2d Cir. 1988) (preclusive effect of underlying judgment on a properly “vouched-in” indemnitor does not extend to issues not actually determined in the first proceeding); Collins v. Miller & Miller, Ltd., 189 Ariz. 387, 397 , 943 P.2d 747, 757 (App. 1996); Dixon, 509 P.2d at 91 (“Neither the doctrine of collateral estoppel nor the vo

2004See Restatement § 57(1)(b), (2), cmt. a (indemnitor only precluded from relitigating issues “determined” in underlying action against indemnitee whether or not parties had conflict of interest); see also SCAC Transport (USA) Inc. v. SS Danaos, 845 F.2d 1157 , 1162 (2d Cir. 1988) (preclusive effect of underlying judgment on a properly “vouched-in” indemnitor does not extend to issues not actually determined in the first proceeding); Collins v. Miller & Miller, Ltd., 189 Ariz. 387, 397 , 943 P.2d 747, 757 (App. 1996); Dixon, 509 P.2d at 91 (“Neither the doctrine of collateral estoppel nor the vo

11
Dixon v. Fiat-Roosevelt Motors, Inc.green
washctapp · 1973 · cited in 1 Arizona opinions naming this issue, 2004–2004
1 sentence

2004See Restatement § 57(1)(b), (2), cmt. a (indemnitor only precluded from relitigating issues “determined” in underlying action against indemnitee whether or not parties had conflict of interest); see also SCAC Transport (USA) Inc. v. SS Danaos, 845 F.2d 1157 , 1162 (2d Cir. 1988) (preclusive effect of underlying judgment on a properly “vouched-in” indemnitor does not extend to issues not actually determined in the first proceeding); Collins v. Miller & Miller, Ltd., 189 Ariz. 387, 397 , 943 P.2d 747, 757 (App. 1996); Dixon, 509 P.2d at 91 (“Neither the doctrine of collateral estoppel nor the vo

11
McIntyre Refrigeration, Inc. v. Mepco Electragreen
arizctapp · 1990 · cited in 1 Arizona opinions naming this issue, 2004–2004
2 sentences

2004That scenario, however, would have precluded Bridgestone’s indemnity liability under § 12-684(A) because that statute premises any indemnity obligation on the manufacturer’s “refus[al] to accept a tender of defense.” Thus, had Bridgestone accepted the tender, A.P.S. would not have had any right to statutory indemnity under § 12-684(A), regardless of the resulting verdict and judgment in the Naranjo case and regardless of any factual determinations made in that case. ¶39 Although A.P.S. still might have pursued a common law claim for indemnity, Bridgestone would have been entitled to raise any

2004That scenario, however, would have precluded Bridgestone’s indemnity liability under § 12-684(A) because that statute premises any indemnity obligation on the manufacturer’s “refus[al] to accept a tender of defense.” Thus, had Bridgestone accepted the tender, A.P.S. would not have had any right to statutory indemnity under § 12-684(A), regardless of the resulting verdict and judgment in the Naranjo case and regardless of any factual determinations made in that case. ¶39 Although A.P.S. still might have pursued a common law claim for indemnity, Bridgestone would have been entitled to raise any

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 (7)

CaseCitedYears
Birch v. Arnold & Sears, Inc. green
mass · 1934
2 sentences

2006No Arizona law suggests that selling an item to an unknown third party is sufficient to meet the tender requirement. ¶39 The Trust also argues it should be permitted to obtain KPNQwest shares and tender those “substitute shares [to] fulfill[] the tender requirement.” The Trust relies primarily on Birch v. Arnold & Sears, Inc., 288 Mass. 125 , 192 N.E. 591 (1934), and Whittier v. Electric Refrigeration Corp., 246 Mich. 247 , 224 N.W. 447 (1929). 6 The court in Birch stated: “The plaintiff having sold some of the securities sold to her by the defendants without knowledge or reason to know of the

2006No Arizona law suggests that selling an item to an unknown third party is sufficient to meet the tender requirement. ¶39 The Trust also argues it should be permitted to obtain KPNQwest shares and tender those “substitute shares [to] fulfill[] the tender requirement.” The Trust relies primarily on Birch v. Arnold & Sears, Inc., 288 Mass. 125 , 192 N.E. 591 (1934), and Whittier v. Electric Refrigeration Corp., 246 Mich. 247 , 224 N.W. 447 (1929). 6 The court in Birch stated: “The plaintiff having sold some of the securities sold to her by the defendants without knowledge or reason to know of the

22006–2006
Whittier v. Elec. Refrigeration Corp. neutral
mich · 1929
2 sentences

2006No Arizona law suggests that selling an item to an unknown third party is sufficient to meet the tender requirement. ¶39 The Trust also argues it should be permitted to obtain KPNQwest shares and tender those “substitute shares [to] fulfill[] the tender requirement.” The Trust relies primarily on Birch v. Arnold & Sears, Inc., 288 Mass. 125 , 192 N.E. 591 (1934), and Whittier v. Electric Refrigeration Corp., 246 Mich. 247 , 224 N.W. 447 (1929). 6 The court in Birch stated: “The plaintiff having sold some of the securities sold to her by the defendants without knowledge or reason to know of the

2006The court in Whittier reached a similar result, holding a plaintiff who tendered shares “equivalent of all he had received” had met the tender requirement for rescission. 224 N.W. at 447 .

22006–2006
Yarbrough v. Montoya-Paez green
arizctapp · 2006
1 sentence

2019And, “[i]f application of a legal principle, even if not raised below, would dispose of an action on appeal and correctly explain the law, it is appropriate for us to consider the issue.” Id. (citation omitted). ¶11 This requires us to review the application of A.R.S. § 12-684(A), which states the following: In any product liability action where the manufacturer refuses to accept a tender of defense from the seller, the manufacturer shall indemnify the seller for any judgment rendered against the seller and shall also reimburse the seller for reasonable 4 OKLAND v. ZURN, et al.

12019–2019
Hill v. Favour green
ariz · 1938
2 sentences

2014He contends that his note was never transferred to Mellon, and because the note and deed of trust are inseparable, citing Hill v. Favour, 52 Ariz. 561, 569 , 84 P.2d 575 (1938), the beneficial interest under the deed of trust was never transferred to Mellon.

2014He contends that his note was never transferred to Mellon, and because the note and deed of trust are inseparable, citing Hill v. Favour, 52 Ariz. 561, 569 , 84 P.2d 575 (1938), the beneficial interest under the deed of trust was never transferred to Mellon.

12014–2014
Whittier v. Electric Refrigeration Corp. neutral
mich · 1929
1 sentence

2006No Arizona law suggests that selling an item to an unknown third party is sufficient to meet the tender requirement. ¶39 The Trust also argues it should be permitted to obtain KPNQwest shares and tender those “substitute shares [to] fulfill[] the tender requirement.” The Trust relies primarily on Birch v. Arnold & Sears, Inc., 288 Mass. 125 , 192 N.E. 591 (1934), and Whittier v. Electric Refrigeration Corp., 246 Mich. 247 , 224 N.W. 447 (1929). 6 The court in Birch stated: “The plaintiff having sold some of the securities sold to her by the defendants without knowledge or reason to know of the

12006–2006
Hellebrandt v. Kelley Co., Inc. green
arizctapp · 1987
2 sentences

2004That scenario, however, would have precluded Bridgestone’s indemnity liability under § 12-684(A) because that statute premises any indemnity obligation on the manufacturer’s “refus[al] to accept a tender of defense.” Thus, had Bridgestone accepted the tender, A.P.S. would not have had any right to statutory indemnity under § 12-684(A), regardless of the resulting verdict and judgment in the Naranjo case and regardless of any factual determinations made in that case. ¶39 Although A.P.S. still might have pursued a common law claim for indemnity, Bridgestone would have been entitled to raise any

2004That scenario, however, would have precluded Bridgestone’s indemnity liability under § 12-684(A) because that statute premises any indemnity obligation on the manufacturer’s “refus[al] to accept a tender of defense.” Thus, had Bridgestone accepted the tender, A.P.S. would not have had any right to statutory indemnity under § 12-684(A), regardless of the resulting verdict and judgment in the Naranjo case and regardless of any factual determinations made in that case. ¶39 Although A.P.S. still might have pursued a common law claim for indemnity, Bridgestone would have been entitled to raise any

12004–2004
Falcon v. Beverly Hills Mortgage Corp. green
ariz · 1991
2 sentences

2004In support of that proposition, Bridgestone relies on Restatement § 57(2)(b), Cunningham , and Falcon v. Beverly Hills Mortgage Corp., 168 Ariz. 527 , 815 P.2d 896 (1991).

2004In support of that proposition, Bridgestone relies on Restatement § 57(2)(b), Cunningham , and Falcon v. Beverly Hills Mortgage Corp., 168 Ariz. 527 , 815 P.2d 896 (1991).

12004–2004

Statutes the citing opinions construe

AZ § Ariz. Rev. Stat. § 12-2101 (4) AZ § Ariz. Rev. Stat. § 12-2506 (3) AZ § Ariz. Rev. Stat. § 12-341.01 (3) AZ § Ariz. Rev. Stat. § 12-681 (3) AZ § Ariz. Rev. Stat. § 12-684 (3)

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

CA 168 (1962–2026) IL 62 (1917–2024) WA 23 (1923–2024) WI 16 (1875–2019) MI 15 (1978–2023) OR 13 (1936–2017) GA 12 (1950–2019) HI 12 (1983–2025) MN 11 (1987–2010) AZ 7 (2004–2019) UT 7 (1989–2024) TX 6 (1919–2018) OH 5 (1910–2020) AK 5 (1976–1993) IN 5 (1985–2017) MD 4 (1972–1984) MO 4 (1986–1999) NE 3 (1891–1996) MT 3 (1944–2009) LA 3 (1931–1986) NY 3 (1919–1947) TN 3 (1883–1991) NJ 2 (2012–2026) CO 2 (1934–1986) NV 2 (1993–2021) ID 2 (1980–1987)

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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