Arizona HOA Transparency Project

Holding HOA Boards, Attorneys, and Management Companies Accountable

Arizona HOA Transparency Project

Maricopa County Superior Court Case CV2021-005014

Case Header

Maricopa County Superior Court Case CV2021-005014: public docket details, parties, minute entries, documents, and official source links for Maricopa Meadows Homeowners Association.

Case Number
CV2021-005014
County
Maricopa
Caption
Not captured
Filed
3/29/2021
Case Type
Civil
Judge
Minder, Scott
Location
Downtown
Official Court Record
Official Court Record

Parties

No parties captured.

Minute Entries

08/04/2021 — CV2021005014 COE, DANIEL 08/04/2021 HONORABLE KATHERINE COOPER View Minute Entry ↑ top

Source
Minute Source
Clerk of the Superior Court

*** Electronically Filed ***

08/10/2021 8:00 AM
SUPERIOR COURT OF ARIZONA
MARICOPA COUNTY

CV 2021-005014

08/04/2021

Docket Code 023
Form V000A
Page 1

CLERK OF THE COURT
HONORABLE KATHERINE COOPER
C. Ladden

Deputy

DANIEL COE
F ROBERT CONNELLY II

v.

MARICOPA MEADOWS HOMEOWNERS
ASSOCIATION
GARY L HUDSON JR.

JUDGE COOPER

RULING RE: MOTION TO DISMISS

The Court has reviewed the Motion to Dismiss filed May 19, 2021; Response filed June
8, 2021; and Reply filed June 21, 2021.

This case arises from a complaint letter sent October 27, 2020 by Defendant Maricopa
Meadows Homeowners Association (“Association”) to the Investigations Division of the United
States Military. The letter stated that Plaintiff Daniel Coe (“COE”), a member of the Arizona
National Guard, was “in violation of numerous military laws relating to his off-base activities
within the Association.” (Exh. 2 to Complaint.) Plaintiff has sued the Association for
defamation. The Association asserts that the letter is privileged and, therefore, the Association
has immunity from suit.

Dismissal is appropriate under Rule 12(b)(6) only if “as a matter of law []plaintiffs would
not be entitled to relief under any interpretation of the facts susceptible of proof.” Coleman v.
City of Mesa, 230 Ariz. 352, 356 (2012) (citing Fid. Sec. Life Ins. Co. v. State Dep't of Ins., 191
Ariz. 222, 224 ¶ 4 (1998)). In considering a motion to dismiss, the Court may consider a
document that is central to the complaint without converting the motion to dismiss to a motion

SUPERIOR COURT OF ARIZONA
MARICOPA COUNTY

CV 2021-005014

08/04/2021

Docket Code 023
Form V000A
Page 2

for summary judgment. ELM Ret. Ctr., LP v. Callaway, 226 Ariz. 287, 289, ¶ 7, 246 P.3d 938,
940 (App. 2010).

A claim for defamation requires proof that the defendant, without legal privilege to do so,
made a false and defamatory statement of fact to a third person and was at least negligent as to
the truth of the statement. Desert Palm Surgical Groupe PLC v. Petta, 236 Ariz. 568 (App.
2015). The existence of a legal privilege in a defamation case is a question of law for the trial
court to resolve. Green Acres Trust. London, 141 Ariz. 609, 613 (1984). An affirmative defense,
such as privilege, may be raised and determined on a motion to dismiss where the facts
constituting the defense appear in the pleadings. Drummond v. Stahl, 127 Ariz. 122, 125
((1980).

In Arizona, an absolute privilege attaches to certain statements by an attorney made to
governing authorities. In Drummond, the Court of Appeals held that an absolute privilege
applied to a lawyer’s statements made in a complaint to the State Bar of Arizona alleging
unethical conduct by an attorney. Similarly, in Sobol v. Alarcon, 212 Ariz. 315 (App. 2006), the
appellate court applied the privilege to an attorney’s complaint to the Arizona Board of Legal
Document Preparers regarding a document preparer and affirmed the dismissal of Sobol’s
defamation action.

In affirming the existence of this privilege, the appellate courts rely on the Restatement
(Second) of Torts 586 which provides an absolute privilege for defamatory statements made in a
judicial proceeding. Drummond, 127 Ariz. at 126. Section 526 states:

An attorney at law is absolutely privileged to publish defamatory matter concerning
another in communications preliminary to a proposed judicial proceeding, or in the
institution of, or during the course and part of, a judicial proceeding in which he
participates as counsel, if it has some relation to the proceeding.

The privilege may apply to a statement that prompts a proceeding even when that
proceeding is not actually underway when the statement is made. In Drummond, the court
applied the privilege even though no investigation or proceedings had been instituted. See also
Ledvina v. Cerasani, 213 Ariz. 569, 572, 574 (App. 2006) (“[a] communication concerning
possible wrongdoing made to an official governmental agency such as a local police department
and which communication is designed to prompt action by that entity is as much a part of an
‘official proceeding’ as a communication made after an official investigation has commenced.”)

Here, the Association’s attorney sent a letter to a governing agency with authority over
Plaintiff as a member of the military. The letter asked the Investigations Division of the United
States Military to investigate Plaintiff for violating Department of Defense Directive 1325.6 and

SUPERIOR COURT OF ARIZONA
MARICOPA COUNTY

CV 2021-005014

08/04/2021

Docket Code 023
Form V000A
Page 3

other provisions of the Uniform Code of Military Justice. The letter was “preliminary to a
proposed judicial proceeding” as evidenced by counsel’s offer to provide witnesses to testify to a
military tribunal regarding Plaintiff’s conduct. It was designed to prompt action by the
Investigations Division.1 Accordingly, the Court finds that the Association’s letter was
privileged and that the Association has immunity from suit.

IT IS ORDERED granting Defendant’s Motion to Dismiss.

IT IS FURTHER ORDERED Defendant shall submit a proposed form of Judgment no
later than two weeks from the date that this ruling is filed with the Clerk of the Court.

1 The Court considers Plaintiff’s argument that there was no connection between the letter and a proceeding against
him and the case relied on by Plaintiff, Edwards v. Centex Real Estate Corp., 53 Ca.. App. 4th 14-15 (Cal. Ct. App.
1997). Edwards is not controlling in the face of Arizona authority directly on point. As stated, an ongoing
proceeding is not necessary for the privilege to apply.

Documents

Type Title Content Type Size Source
minute_entry_pdf CV2021005014 COE, DANIEL 08/04/2021 HONORABLE KATHERINE COOPER View Minute Entry application/pdf 130.1 KB Document Source

Auto-compiled from public records, pending verification

Review the official court record for the current docket.

To request a correction or removal, contact the site administrator.