State of Arizona v. Bhajanpal Chopra
241 Ariz. 353
| Ariz. Ct. App. | 2016Background
- In Feb. 2015 Chopra was charged in justice court with DWI and having BAC ≥ .08; a blood sample was taken and tested.
- Chopra moved for disclosure of all chromatograms and batch data for every sample tested on the same date to assess reliability of lab testing.
- The state opposed disclosure as irrelevant and a fishing expedition; the justice court granted Chopra’s motion.
- The state filed a special-action petition in superior court challenging the disclosure order.
- The superior court declined to accept special-action jurisdiction, concluding the trial court’s order was not clearly erroneous and noting the disclosure required was limited.
- The state appealed to the Court of Appeals; the appellate court considered whether it had jurisdiction and whether the superior court abused its discretion in declining jurisdiction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Appellate jurisdiction over superior court decision on special action | State: § 12‑2101 authorizes appeal from superior court special-action final judgment | Chopra: no subsection of § 13‑4032 authorizes state appeal; special action is civil so § 12‑2101 controls | Court: § 12‑2101(A)(1) provides jurisdiction; appellate review appropriate under prior cases |
| Nature of superior court order (accepted jurisdiction vs declined) | State: court effectively ruled on merits because it said trial court did not abuse discretion | Chopra: court explicitly declined jurisdiction; statement about trial court was explanatory | Court: superior court declined special-action jurisdiction; explanatory finding not a merits ruling |
| Standard of review on appeal | State: should be merits review if superior court ruled on correctness | Chopra: only abuse-of-discretion review applies when superior court declines jurisdiction | Court: because superior court declined jurisdiction, only abuse-of-discretion review applies |
| Whether superior court abused discretion in declining jurisdiction | State: superior court should have accepted special action to resolve discovery scope | Chopra: superior court reasonably declined because trial court’s ruling not clearly erroneous and disclosure limited | Court: no abuse of discretion — superior court reasonably declined (no plain error, limited disclosure, discovery disputes generally not grounds for special action) |
Key Cases Cited
- Ghadimi v. Soraya, 230 Ariz. 621 (clarifies appellate court must independently examine jurisdiction)
- State v. Bayardi, 230 Ariz. 195 (appellate jurisdiction is statutory)
- Pinal Vista Props., L.L.C. v. Turnbull, 208 Ariz. 188 (more specific statute controls over general statute)
- State v. Cooperman, 230 Ariz. 245 (appeals from superior court special actions in DUI context use § 12‑2101)
- Bohsancurt v. Eisenberg, 212 Ariz. 182 (same; treating special-action review as civil)
- Stapert v. Ariz. Bd. of Psychologist Exam’rs, 210 Ariz. 177 (bifurcated review: did superior court accept jurisdiction?)
- Files v. Bernal, 200 Ariz. 64 (if superior court declines jurisdiction, review limited to abuse of discretion)
- Amos v. Bowen, 143 Ariz. 324 (special action may be appropriate where trial court committed plain and obvious error)
- Sanchez v. Gama, 233 Ariz. 125 (special action may be warranted for issues of statewide importance)
- Jolly v. Superior Court, 112 Ariz. 186 (extraordinary relief is not routinely granted for discovery disputes)
- Yuma Reg’l Med. Ctr. v. Superior Court, 175 Ariz. 72 (special action generally inappropriate to resolve discovery disputes)
- Lang v. Superior Court, 170 Ariz. 602 (same)