Arizona HOA Transparency Project

Holding HOA Boards, Attorneys, and Management Companies Accountable

Arizona HOA Transparency Project

HOA Court Cases

Arizona court rulings applicable to HOA law, organized by court level. Each card starts with why the ruling matters for HOA boards, homeowners, and counsel.

Federal Court

Federal court rulings involving Arizona HOA disputes, debt collection claims, lending issues, or federal statutes that affect homeowners and associations.

6 cases

Six v. IQ Data International, Inc.

129 F.4th 630 (9th Cir. 2025)
Federal Court · February 24, 2025 · Consumer Ryan Six (Plaintiff-Appellant) v. debt collector IQ Data International, Inc. (De…
Why it matters
Six resolves an important standing question for consumer-protection litigation in the Ninth Circuit: a single unwanted written communication sent to a represented consumer can, by itself, be a concrete injury sufficient to sue in federal court. By anchoring the injury in Congress’s privacy findings and the common-law…
fdcpaprocedureattorneys-fees
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Janis Wolf, Plaintiff, v. Carpenter Hazlewood Delgado & Bolen LLP, Defendant.

No. CV-20-00957-PHX-DLR
Federal Court · January 18, 2022 · Janis Wolf (Plaintiff) v. Carpenter Hazlewood Delgado & Bolen LLP (Defendant)
Why it matters
For Arizona homeowners and HOAs, the decision addresses a recurring question: whether an HOA’s collection law firm may pull a delinquent owner’s credit report without consent. By treating the installment-based annual assessment as a voluntary “credit transaction,” the court gave collection firms a permissible-purpose…
assessmentscc-and-rsprocedurefdcpa
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Glawe v. Carpenter, Hazlewood, Delgado & Bolen PLC

9th Cir. No. 19-17090 (memorandum disposition)
Federal Court · June 8, 2021 · Curtis G. Glawe (pro se homeowner and HOA member) v. Carpenter, Hazlewood, Delgado & Bole…
Why it matters
For Arizona homeowners and community associations, this memorandum illustrates a recurring dividing line in assessment-collection disputes: whether the FDCPA even applies to an HOA’s efforts to collect unpaid dues. The FDCPA governs only “consumer” debt, and the Ninth Circuit’s analysis makes clear that the character…
fdcpaassessmentscc-and-rsattorneys-feesprocedure
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McNair v. Maxwell & Morgan, PC

893 F.3d 680 (9th Cir. 2018) (No. 15-17383)
Federal Court · June 25, 2018 · Martha A. McNair (Plaintiff-Appellant, a Gilbert homeowner) v. Maxwell & Morgan PC and it…
Why it matters
This published Ninth Circuit decision is significant for homeowners, associations, and the law firms that collect HOA debt because it confirms that the FDCPA applies to judicial-foreclosure collection of delinquent assessments. Many collectors had read Ho v. ReconTrust to mean that any foreclosure is outside the Act.…
fdcpaassessmentsforeclosureattorneys-feeslienscc-and-rs
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Zakia Mashiri v. Epsten Grinnell & Howell; Debora M. Zumwalt; Does 1-25

845 F.3d 984 (9th Cir. 2017) (No. 14-56927)
Federal Court · January 13, 2017 · Zakia Mashiri (Plaintiff-Appellant), a homeowner and member of the Westwood Club homeowne…
Why it matters
For homeowners’ associations and the law firms that collect their assessments, this published Ninth Circuit decision confirms that a single letter can be both a Davis-Stirling pre-lien notice and full-blown FDCPA debt collection. A collector cannot escape § 1692g simply by saying it was ‘perfecting a security interest…
fdcpaassessmentsliensforeclosureprocedure
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In re Shawn Burgueno, Debtor

451 B.R. 1 (Bankr. D. Ariz. 2011)
Federal Court · May 26, 2011 · Edge at Grayhawk Condominium Association and Grayhawk Community Association (Creditors/Re…
Why it matters
This published bankruptcy decision is frequently cited for the proposition that an individual debtor’s personal liability for homeowner- and condominium-association assessments does not stop at the bankruptcy filing or at stay relief—it continues, post-petition, for as long as the debtor holds legal title to the unit.…
bankruptcyliensassessmentsattorneys-feescc-and-rsforeclosure
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