Arizona Board of Regents v. Arizona York Refrigeration Co.
565 P.2d 518 · Arizona Supreme Court · 1977
Facts
York repaired a boiler at Northern Arizona University (NAU). Hartford, NAU's insurer, initially authorized repairs for $8,437. When additional work was deemed necessary, Hartford's inspector authorized it. York completed repairs totaling $14,584.22, but Hartford only offered the initial amount. York sued both the Arizona Board of Regents and Hartford.
Issue
1. Did York properly obtain consent to sue the state (Board of Regents) by complying with statutory claims procedures? 2. Did Hartford's conduct create an obligation to pay for the additional repairs beyond the initial agreement? 3. Should York's judgment be limited to the original repair amount?
Holding
The court reversed the judgment against the Board of Regents, finding York failed to comply with state claims statutes by filing an untimely claim. The court affirmed the judgment against Hartford, holding Hartford was obligated to pay the full reasonable value of $14,584.22 for all authorized repairs based on an implied contract.
Rule
Suits against the state require strict compliance with statutory claims procedures, including timely filing, as a prerequisite for jurisdiction. An implied contract can arise from the acts and conduct of parties and surrounding circumstances, obligating a party to pay the reasonable value of services rendered when authorized.
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