The Arizona Supreme Court vacated a Court of Appeals decision in *Sanchez v. Maricopa County*, a case that centers on whether a county can be held vicariously liable for the negligence of a deputy sheriff who caused an accident while performing law enforcement duties.
The high court's July 21, 2025 ruling overturned the Court of Appeals Division One decision from 2023, which had affirmed a superior court ruling. The case involves five members of the Lopez Sanchez family as plaintiffs against Maricopa County.
Justice Montgomery authored the unanimous opinion for the court, joined by Chief Justice Timmer, Vice Chief Justice Lopez, and Justices Bolick, Beene, King, and retired Justice Brutinel. The court addressed fundamental questions about governmental liability under the doctrine of respondeat superior.
Under respondeat superior, an employer can be vicariously liable for an employee's negligence if the employee is under the employer's control when an accident occurs, as established in *Engler v. Gulf Interstate Engineering, Inc.* (2012). The central legal question in *Sanchez* involves whether this doctrine applies to county governments when deputy sheriffs cause accidents during their official duties.
The case also examines the scope of the Arizona Claims Act, which governs when governmental entities can be held liable for damages. The intersection of these legal principles creates complex questions about when counties must answer for their law enforcement officers' actions.
The original lawsuit was filed in Maricopa County Superior Court under case number CV2022-092441, with Judge Rodrick J. Coffey presiding. The superior court initially ruled in favor of Maricopa County, a decision that was later affirmed by the Court of Appeals.
The plaintiffs are represented by David L. Abney of Ahwatukee Legal Office and Chase W. Rasmussen and Alexander M. Hyde of Rasmussen Injury Law in Mesa. Maricopa County is represented by County Attorney Rachel H. Mitchell and Deputy County Attorneys Pamela A. Hostallero and Sean M. Moore.
The case has drawn attention from the Arizona Association for Justice, which filed an amicus curiae brief. The organization was represented by Larry J. Wulkan and Peter A. Silverman of Zwillinger Wulkan PLC in Phoenix.
The Supreme Court's decision to vacate the appeals court ruling suggests the justices found errors in the lower court's analysis or application of law. When an appellate court vacates a decision, it nullifies the ruling and typically requires further proceedings or reconsideration of the legal issues.
This case has significant implications for governmental liability in Arizona. Counties employ numerous deputy sheriffs who regularly engage in high-risk activities including traffic stops, pursuits, and emergency responses. The question of when counties bear financial responsibility for accidents during these activities affects both public safety operations and taxpayer liability.
The doctrine of respondeat superior traditionally holds employers liable for employee actions within the scope of employment. However, governmental entities often enjoy certain immunities and protections under state law that private employers do not possess.
The Arizona Claims Act provides the framework for when governmental entities can be sued and held liable for damages. This statute balances the need to compensate injured parties against the principle that taxpayers should not bear unlimited liability for government operations.
Law enforcement activities present particularly complex liability questions. Deputy sheriffs must make split-second decisions in dangerous situations, and their actions can have serious consequences for public safety and individual rights. Courts must balance holding governments accountable while not discouraging necessary law enforcement activities.
The *Sanchez* case appears to involve an accident caused by a deputy sheriff during official duties, though the specific facts of the underlying incident are not detailed in the available court documents. The nature of the deputy's actions and the circumstances of the accident likely played crucial roles in the legal arguments.
With the appeals court decision now vacated, the case may return to lower courts for further proceedings or the Supreme Court may issue new guidance on the liability questions. The vacation of the appeals court ruling gives the Lopez Sanchez family new opportunities to pursue their claims against Maricopa County.
The unanimous nature of the Supreme Court's decision suggests broad agreement among the justices that the appeals court's analysis required correction. This consensus indicates the legal issues may be clearer than the lower courts initially recognized.
The case represents broader questions about governmental accountability in Arizona. As counties face increasing demands for public safety services while managing limited budgets, liability rules significantly impact both service delivery and fiscal planning.
The *Sanchez* decision will likely influence how Arizona courts analyze similar cases involving law enforcement liability and may prompt counties to review their risk management practices and insurance coverage for deputy sheriff activities.