Espinoza v. Schulenburg: Arizona Adopts the Rescue Doctrine and Firefighter’s Rule

In its first case considering the issue, the Arizona Supreme Court followed the Restatement (Third) of Torts Section 32 and adopted the rescue doctrine, which permits an injured rescuer to recover from the person whose tortious conduct necessitated the rescue. The court also adopted a narrow version of the firefighter’s rule, a limitation on the rescue doctrine, and concluded that firefighters who arrive at a rescue scene as a result of their on-duty obligations as firefighters may not recover in tort under the rescue doctrine.