Lee v. State: The Mailbox Rule and its Applicability to Notices of Claims Against the State

In Lee v. State, the Arizona Supreme Court held that filing a notice of claim against a public entity may be accomplished through regular mail, and that proof of mailing is evidence that the public entity actually received the notice. Additionally, the Court held that if the claimant presents proof of proper mailing of the notice of claim and the public entity denies receipt, the fact finder must determine whether the claim was, in fact, received within the statutory deadline.