In 1990, Arizona voters passed the Victims’ Bill of Rights. Codified as Article II, § 2.1 of the Arizona Constitution, the bill created 12 enumerated rights designed to safeguard crime victims’ right to fair treatment and to ensure meaningful participation in the criminal-justice process. Among those rights is that codified in A.R.S. § 13-4433(B), which requires a defendant or the defendant’s attorney to initiate contact with a victim through the prosecutor’s office. Early challenges to the statute on due process grounds to the provision failed. Now a new challenge, Arizona Attorneys for Criminal Justice v. Ducey, pits victims’ rights not against defendants’ due process rights—but against defense attorneys’ First Amendment rights.