ARS 32-1132 Interpretation

In Shelby v. Ariz. Registrar of Contractors, 172 Ariz. 95, 101, 834 P.2d 818, 824 (1992), the Arizona Supreme Court noted the difference between administrative proceedings and court actions in the context of a claim for attorney fees by a claimant whose appeal arose "from a direct action brought by the claimant against the contractor in superior court." 172 Ariz. at 101, 834 P.2d at 824. Because A.R.S. 32-1132, which provides for attorney fee awards in proceedings before the Registrar, did not apply to the claimant's action, the supreme court determined no fees were awardable. 172 Ariz. at 101, 834 P.2d at 824.