Camboni v. Golden Hills, 1 CA-CV 15-0213

Background

Plaintiffs (Shannon Chaboudy, Anthony Camboni, and the corporate entity You’ve Got Better Things to Do (YGBTTD)) sued Golden Hills HOA and others for disputes arising from web‑hosting/management services contracts.
Chaboudy signed the complaint on behalf of YGBTTD; YGBTTD never retained counsel and is a corporate entity that must appear through licensed counsel.
Camboni, an unlicensed attorney, filed appearances and pleadings on behalf of Chaboudy and YGBTTD despite repeated court admonitions that non‑lawyers may only represent themselves.
The superior court struck the amended complaint (Rule 15), dismissed YGBTTD’s claims for lack of counsel, and later granted Defendants’ motion to dismiss for insufficient/untimely service and failure to state a claim, entering final judgment.
On appeal, YGBTTD was dismissed for failing to appear through counsel; Chaboudy did not prosecute the appeal; only Camboni (pro se) remained as appellant.
The appellate court found Camboni’s brief noncompliant with ARCAP, lacking record citations and legal argument, and affirmed the superior court; it also authorized attorneys’ fees to Defendants for a frivolous appeal.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a non‑lawyer (Camboni) may represent other plaintiffs or a corporation in court	Camboni argued broadly against the rule that non‑lawyers cannot represent others (challenging regulation of practice)	Defendants argued non‑lawyers cannot represent other parties; corporations must be represented by counsel	Court reaffirmed that non‑lawyers may only represent themselves; corporation must appear through licensed counsel (Hunt/Eliot)
Whether YGBTTD’s claims were properly dismissed for lack of counsel and defective service	Plaintiffs contended procedural errors and sought more time to retain counsel	Defendants argued dismissal was proper because YGBTTD had no counsel and service was insufficient/untimely	Court affirmed dismissal of YGBTTD’s claims for lack of counsel and upheld dismissal for insufficient/untimely service
Whether Camboni’s appellate brief complied with ARCAP and fairly raised issues	Camboni submitted an opening brief attacking authorization rules and asserting errors without record citations	Defendants argued the brief failed to comply with ARCAP and abandoned issues by not citing record or law	Court held Camboni’s brief noncompliant and that arguments were waived; appellants must present developed, cited arguments
Whether the superior court abused discretion by denying additional time to respond to motion to dismiss	Camboni sought a 90‑day extension claiming other commitments	Defendants asserted prior extensions were ample and no good cause existed for more delay	Court found no abuse of discretion; prior admonitions and delays justified denying additional time

Key Cases Cited

Hunt Inv. Co. v. Eliot, 154 Ariz. 357 (App. 1987) (non‑lawyers may not represent other parties)
Ace Automotive Products, Inc. v. Van Duyne, 156 Ariz. 140 (App. 1987) (appellate courts are not required to develop a litigant’s argument)
Higgins v. Higgins, 194 Ariz. 266 (App. 1999) (pro se litigants are held to the same procedural standards as attorneys)
State v. Moody, 208 Ariz. 424 (2004) (failure to adequately present issues can constitute abandonment or waiver)
State Farm Mut. Auto. Ins. Co. v. Novak, 167 Ariz. 363 (App. 1990) (appellate courts may refuse to consider arguments that fail to comply with appellate rules)