City of Phoenix v. Fields and Backus v. State: Undoing Deer Valley’s Damage

In the 2007 case Deer Valley Unified School District No. 97 v. Houser, the Arizona Supreme Court held that claims against the State must strictly adhere to Arizona’s notice of claim statute, which requires that a claim “contain a specific amount for which the claim can be settled and the facts supporting that amount.” While Deer Valley “abrogated seventeen years of case precedent that set ‘reasonableness’ as the standard to measure whether a notice of claim against a public entity satisfies the statute,” City of Phoenix v. Fields and Backus v. State largely restore reasonableness to the statute’s interpretation and application.