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Contempo-Tempe Mobile Home Owners Ass'n v. Steinert

Citations: 144 Ariz. 227; 696 P.2d 1376; 1985 Ariz. App. LEXIS 463Docket: 1 CA-CIV 6961

Court: Court of Appeals of Arizona; January 17, 1985; Arizona; State Appellate Court

Narrative Opinion Summary

The case involved appellant associations challenging a rent increase imposed by operators of a mobile home park, alleging a failure to negotiate in good faith. Initially, the trial court found that the appellants lacked standing, allowing them to amend their complaint to include individual tenants. Subsequently, a stipulation to dismiss the case with prejudice was reached between the individual tenants and the appellees, resolving the substantive issues. The appellants appealed the standing determination; however, the appellate court dismissed the appeal as moot, given there was no longer an active controversy. The court underscored the constitutional limitations on federal court jurisdiction over moot questions and highlighted that this case did not meet the criteria for exceptions to mootness, such as presenting a matter of significant public interest. Despite the appellees not moving to dismiss for mootness, the court independently identified and applied the mootness doctrine, referencing established precedents. Judges HAIRE and BROOKS concurred in dismissing the appeal on these grounds.

Legal Issues Addressed

Exceptions to Mootness

Application: The court affirmed that this case did not qualify for exceptions to mootness, as it neither presented issues capable of repetition yet evading review nor questions of significant public interest.

Reasoning: The court notes that it does not decide moot questions and that the current case does not meet exceptions for being capable of repetition yet evading review or presenting a question of public importance.

Mootness Doctrine in Appeals

Application: The court applied the mootness doctrine to dismiss the appeal, as there was no longer an active case or controversy following the stipulation to dismiss the case with prejudice.

Reasoning: The court ruled that the appeal by the appellant associations is dismissed due to mootness, meaning there is no active case or controversy.

Standing to Sue under Arizona Mobile Home Parks Residential Landlord and Tenant Act

Application: The appellants' inquiry into the standing of mobile home tenant associations was rendered moot due to the dismissal of the case, thus the court did not provide a determination on this legal question.

Reasoning: Appellants seek a judicial determination on whether mobile home tenant associations possess standing to sue under the Arizona Mobile Home Parks Residential Landlord and Tenant Act. However, this inquiry is moot due to the prior stipulation that dismissed the case with prejudice, resolving any substantive issues.