Arizona State Board of Dental Examiners v. Hyder

In Arizona State Board of Dental Examiners v. Hyder, 114 Ariz. 544, 562 P.2d 717 (1977), the Arizona State Board of Dental Examiners had sought to enjoin two parties from practicing dentistry without a license. Id. at 545, 562 P.2d at 718. The trial court found that the parties had not been practicing dentistry and refused to enjoin their conduct. Id. The supreme court noted the "overwhelming and uncontradicted" evidence that the parties had been practicing dentistry. Id. at 546, 562 P.2d at 719. It then addressed whether the Board should have been required to show injury and irreparable harm before the trial court could grant an injunction. Id. The court concluded that there was no such requirement. Id. It also noted that the legislature had declared the licensing requirement to be in the public interest and had provided injunctive relief as a remedy for practicing dentistry without a license. Id. Under those circumstances, the court held, the trial court had no discretion to deny injunctive relief. Id.