Estate of Braden ex rel. Gabaldon v. State and Statutory Construction in the Arizona Supreme Court

In *Estate of Braden*, the Arizona Supreme Court held 3−2 that the State of Arizona could not be a defendant under section 46-455 of the Adult Protective Services Act. The majority and the dissent both employed a comprehensive set of statutory interpretation tools in their analysis. This Case Note explores how the court used these tools of interpretation in Estate of Braden and in other recent decisions to illustrate how the current court analyzes ambiguous statutes. It concludes with two general observations about the Arizona Supreme Court’s statutory interpretation theories. First, the court adheres closely to the text and is not easily persuaded to read requirements into statutes. Second, the court is open to considering a wide range of tools and sources when discerning the meaning of an ambiguous statute.