Notice of Claims and the “Sum Certain” Requirement: The Fallout from Deer Valley

In Deer Valley Unified School District No. 97 v. Houser, the Arizona Supreme Court held that claims against a public entity must strictly adhere to Arizona’s notice of claims statute, which requires that a claim must “contain a specific amount for which the claim can be settled.” While the decision gave the State a powerful weapon to protect itself from civil tort liability, Deer Valley has caused confusion and uncertainty among claimants, public entities, lawyers, and state and federal courts.