David Stambaugh v. Mark Killian, 242 Ariz. 508

Eureka Springs applied to record a "bar seven" brand in Arizona; an identical brand was already recorded by David Stambaugh.
The difference: Eureka Springs proposed to place the identical bar-seven on the left rib; Stambaugh’s brand was on the left hip.
The Department of Agriculture initially rejected Eureka Springs’ application but supervisors later approved it because the brands differed in location.
Stambaugh protested; the Department denied the protest and recorded Eureka Springs’ brand.
Stambaugh sued; the superior court granted the Department partial summary judgment and remanded for administrative hearing. The court of appeals affirmed, finding § 3-1261(B) ambiguous and allowing location to distinguish brands.
The Arizona Supreme Court granted review to resolve whether A.R.S. § 3-1261(B) prohibits recording identical brands solely because they are placed in different locations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether A.R.S. § 3-1261(B) prohibits recording two brands of the same "design or figure" regardless of placement	Stambaugh: "Design or figure" refers only to the pattern/shape; location is distinct and does not allow identical designs to be separately recorded	Department: statute is ambiguous; agency may consider location and has discretion to record identical designs in different locations to serve identification and theft-prevention purposes	The Court held § 3-1261(B) is unambiguous: "design or figure" excludes location; identical designs cannot be recorded even if placed differently
Whether the Court should defer to the Department's contrary interpretation	Stambaugh: no deference necessary because the statute is clear	Department: agency expertise and longstanding practice justify deference (Chevron-style)	The Court refused deference because the legislature spoke clearly; agency interpretation not given weight

Wade v. Arizona State Retirement System, 241 Ariz. 559 (Court discusses de novo statutory interpretation)
Stambaugh v. Butler, 240 Ariz. 363 (Court of Appeals decision affirming agency discretion to consider location)
State v. Pena, 235 Ariz. 277 (use common meaning where statute does not define term)
State v. Sweet, 143 Ariz. 266 (ambiguity analysis and examining statute as a whole)
City of Tucson v. Clear Channel Outdoor, Inc., 209 Ariz. 544 (avoid interpretations rendering clauses superfluous)
City of Flagstaff v. Mangum, 164 Ariz. 395 (do not read omitted terms from one provision into another)
State v. Christian, 205 Ariz. 64 (declining to resort to other canons once statute is plain)