Estate of braden/gabaldon v. State
266 P.3d 349
Ariz.2011Background
- Adult Braden, with developmental disabilities, used AIRES services contracted with DES's Division of Developmental Disabilities.
- In 2005 Braden died from injuries at an AIRES facility; his estate sued the State asserting APSA civil damages claim for abuse/neglect.
- The State moved for summary judgment arguing it was not a proper APSA defendant; trial court granted summary judgment in the State's favor.
- Court of Appeals reversed in part, suggesting the State could be liable under APSA as an enterprise.
- Arizona Supreme Court granted review to resolve whether the State falls within APSA’s liability provisions and whether the State may be liable at all.
- The Court holds APSA does not expose the State to damages under § 46-455(B) as interpreted in the statute and its definitions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether APSA § 46-455(B) permits damages against the State. | Estate argues the State may be an “enterprise.” | State contends it is not included in the statutory definitions. | No; the State is not an APSA defendant. |
| Whether the term “enterprise” in § 46-455(Q) includes the State. | Estate asserts the State is a “legal entity” and thus an enterprise. | Majority reads “labor union or other legal entity” to imply private entities; state not included. | State not included as an “enterprise.” |
| Role of statutory canons and context in interpreting APSA’s scope. | Remedial nature supports broader liability. | Remedial intent does not override textual limits on who may be liable. | Text and context do not support including the State; interpret narrowly to exclude the State. |
Key Cases Cited
- Estate of Winn, 214 Ariz. 149 (2007) (remedial construction informs interpretation of APSA)
- State v. Christian, 205 Ariz. 64 (2003) (plain meaning governs if text unambiguous)
- State ex rel. Bohannon v. Smith, 101 Ariz. 520 (1966) (state as legal entity; not a general rule for all statutes)
- Backus v. State, 220 Ariz. 101 (2009) (general liability rules vs. statutory limitations for public entities)
- Estate of Braden, 225 Ariz. 391 (App. 2010) (discusses whether State exempt from § 46-455(B) liability)