Thanks for visiting! Welcome to a new way to research case law. You are viewing a free summary from Descrybe.ai. For citation and good law / bad law checking, legal issue analysis, and other advanced tools, explore our Legal Research Toolkit — not free, but close.
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
The court ruled that the appeal by the appellant associations is dismissed due to mootness, meaning there is no active case or controversy. The appellants initially filed a complaint against the operators of a mobile home park, seeking an injunction against a rent increase and damages for not negotiating in good faith. The trial court determined that the appellants lacked standing, allowing them to amend the complaint to include individual tenants. Subsequently, the individual tenants and the appellees reached a stipulation to dismiss the case with prejudice, which the court accepted. The appellants then appealed the trial court's initial ruling on standing; however, since the substantive issues were resolved by the dismissal, the appeal was moot. The court emphasized its inability to render decisions on moot questions, referencing constitutional limitations on federal court jurisdiction and previous Arizona case law on mootness. While Arizona courts can consider moot questions in cases of significant public interest, this appeal did not meet that standard. 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. Citing precedents, such as Webber v. Smith and State Farm Automobile Insurance Company v. Civil Service Employees Insurance Company, the court emphasizes that a case is moot when it no longer presents an actual controversy, particularly when a change in circumstances, like a stipulation, eliminates the underlying issues. 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. Although the appellees did not move to dismiss for mootness, the court identifies mootness independently and dismisses the appeal accordingly. Judges HAIRE and BROOKS concur in this decision.