American Medical v. Central Az

CourtCourt of Appeals of Arizona
DecidedNovember 10, 2025
Docket1 CA-CV 24-0767
StatusUnpublished

This text of American Medical v. Central Az (American Medical v. Central Az) is published on Counsel Stack Legal Research, covering Court of Appeals of Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
American Medical v. Central Az, (Ark. Ct. App. 2025).

Opinion

NOTICE: NOT FOR OFFICIAL PUBLICATION. UNDER ARIZONA RULE OF THE SUPREME COURT 111(c), THIS DECISION IS NOT PRECEDENTIAL AND MAY BE CITED ONLY AS AUTHORIZED BY RULE.

IN THE ARIZONA COURT OF APPEALS DIVISION ONE

AMERICAN MEDICAL RESPONSE, INC., et al., Plaintiffs/Appellants,

v.

JENNIFER CUNICO, in her official capacity as the Executive Director of the Arizona Department of Health Services, et al., Defendants/Appellees.

No. 1 CA-CV 24-0767 FILED 11-10-2025

Appeal from the Superior Court in Maricopa County No. CV2023-014098 The Honorable John L. Blanchard, Judge

AFFIRMED

COUNSEL

Snell & Wilmer LLP, Phoenix By Brett William Johnson, Tracy Olson, and Claudia E. Stedman Co-Counsel for Plaintiffs/Appellants

Shorall McGoldrick Zerlaut, Phoenix By Paul J. McGoldrick Co-Counsel for Plaintiffs/Appellants AMERICAN MEDICAL, et al. v. CENTRAL AZ, et al. Decision of the Court

Papetti Samuels Weiss McKirgan LLP, Scottsdale By Lauren Ann Crawford and Robert H. McKirgan Counsel for Defendant/Appellee Central Arizona Fire and Medical

Arizona Attorney General’s Office, Phoenix By Patricia Cracchiolo LaMagna, Hayleigh S. Crawford, Mary Curtin, and Luci Danielle Davis Counsel for Defendants/Appellees Arizona Department of Health Services and Jennifer Cunico

Arizona Attorney General’s Office, Phoenix By Alexander W. Samuels and Mary Curtin Counsel for Defendant/Appellee Kristin K. Mayes

MEMORANDUM DECISION

Judge Veronika Fabian delivered the decision of the Court, in which Presiding Judge James B. Morse Jr. and Judge Anni Hill Foster joined.

F A B I A N, Judge:

¶1 American Medical Response, Inc. and its subsidiary Life Line, Inc. (collectively “American Medical”) appeal from the superior court’s dismissal of its quo warranto claim and of Defendant Jennifer Cunico, Executive Director of the Arizona Department of Health Services (“the Department”). On appeal, American Medical argues that it stated a claim for quo warranto and that the Department was a necessary party to the remaining counts. This Court disagrees and affirms.

FACTUAL AND PROCEDURAL BACKGROUND

¶2 Central Arizona Fire and Medical Authority (“Fire District”) is a fire district and a special taxing district located in Yavapai County. American Medical operates an ambulance service within the Fire District’s boundaries. In 2022, the Fire District instituted a new fee schedule through Resolution 2022-06 (“the Resolution”), which includes a $550 paramedic ride-along fee applied to ambulance service providers operating within the district.

2 AMERICAN MEDICAL v. CENTRAL AZ Decision of the Court

¶3 In 2023, American Medical challenged the Fire District’s authority to impose that fee. American Medical subsequently amended its complaint to join the Department and Kristin Mayes in her capacity as Attorney General of Arizona (collectively “the Attorney General”). American Medical asserted the Fire District was unlawfully usurping the Department’s exclusive authority to regulate ambulance service providers and sought declaratory relief to stop the Fire District from doing so.

¶4 The superior court dismissed both the Department and the Attorney General, finding American Medical failed to state a claim for relief against either. The court further found American Medical and the Fire District were “the appropriate parties to this dispute.” Upon the parties’ request, the court entered a Rule 54(b) judgment, which dismissed American Medical’s quo warranto claim against all parties. American Medical appealed the portion of the order dismissing its quo warranto claim and the Department. This Court has jurisdiction pursuant to Article VI, Section 9, of the Arizona Constitution and A.R.S. §§ 12-120.21(A)(1) and 2101(A)(1).

DISCUSSION

¶5 American Medical argues A.R.S. § 36-2232(A) provides nearly exclusive authority to the Department to regulate charges for ambulance- related services. It claims the Fire District, by adopting Resolution 2022-06, unlawfully usurped the Department’s fee-setting authority. American Medical asserts that Count IV, which it describes as a request for “a declaration that a quo warranto claim exists” against the Department, should not have been dismissed because the Uniform Declaratory Judgments Act (“UDJA”), A.R.S. §§ 12-1831 to 1846, entitles American Medical to such relief. Alternatively, it argues that because the Department is a necessary party, it should not have been dismissed.

¶6 This Court reviews dismissal of a complaint under Rule 12(b)(6) de novo. Shepherd v. Costco Wholesale Corp., 250 Ariz. 511, 513 ¶ 11 (2021). “When adjudicating a Rule 12(b)(6) motion to dismiss, Arizona courts look only to the pleading itself and consider the well-pled factual allegations contained therein.” Cullen v. Auto-Owners Ins. Co., 218 Ariz. 417, 419 ¶ 7 (2008). “Courts must also assume the truth of the well-pled factual allegations and indulge all reasonable inferences therefrom.” Id.

I. American Medical Failed to State a Claim in Quo Warranto.

¶7 “An action in quo warranto is an extraordinary proceeding, addressed to preventing a continued exercise of authority unlawfully

3 AMERICAN MEDICAL v. CENTRAL AZ Decision of the Court

asserted.” State ex rel. Woods v. Block, 189 Ariz. 269, 272 (1997). Arizona’s quo warranto statute can be found at A.R.S. §§ 12-2041 to 2045. Section 12-2041 authorizes the attorney general to bring an action:

against any person who usurps, intrudes into or unlawfully holds or exercises any public office or any franchise within this state.

A private party may only bring a quo warranto action, with leave of the court, if they are the “person claiming such office or franchise” and if the attorney general or county attorney “refuses to bring an action as provided for in §§ 12-2041 and 12-2042.” A.R.S. § 12-2043. Arizona law does not allow a private party, other than one whose office is being usurped, to bring a petition for a writ of quo warranto. See State ex rel. Sawyer v. LaSota, 119 Ariz. 253, 255 (1978). Because American Medical is not a “person claiming such office or franchise,” it cannot bring a quo warranto claim as a matter of law.

¶8 In its opening brief, American Medical argued it may seek declaratory relief under the UDJA that a quo warranto claim exists because the Resolution usurps the authority of the Department. Admitting this is a “novel” argument, it contended the “plain language” of the UDJA allows such relief because it says a court may “declare rights, status, and other legal relations whether or not further relief is or could be claimed.” A.R.S. § 12-1831. However, at oral argument, American Medical conceded the Arizona Supreme Court’s decision in Skinner v. City of Phoenix, 54 Ariz. 316 (1939), precludes its quo warranto claim.

¶9 American Medical’s requested relief—a declaration that it has a quo warranto claim against the Department—is not available under either the UDJA or the quo warranto statutes. Therefore, the superior court did not err by dismissing Count IV for failure to state a claim upon which relief can be granted. See Ariz. R. Civ. P. 12(b)(6).

II.

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Related

Cullen v. Auto-Owners Insurance
189 P.3d 344 (Arizona Supreme Court, 2008)
State Ex Rel. Sawyer v. LaSota
580 P.2d 714 (Arizona Supreme Court, 1978)
State Ex Rel. Woods v. Block
942 P.2d 428 (Arizona Supreme Court, 1997)
Skinner v. City of Phoenix
95 P.2d 424 (Arizona Supreme Court, 1939)
Heritage v. Weinberg
443 P.3d 964 (Court of Appeals of Arizona, 2019)

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American Medical v. Central Az, Counsel Stack Legal Research, https://law.counselstack.com/opinion/american-medical-v-central-az-arizctapp-2025.