Andreola v. Ariz. Bank
In Andreola v. Ariz. Bank, 26 Ariz. App. 556, 558, 550 P.2d 110, 112 (1976), however, the Court expanded the reach of an FED action by holding forcible detainer was not limited to the formal landlord-tenant situation. 26 Ariz. App. at 559, 550 P.2d at 113.
The Court held a holder of a trustee's deed could bring an FED action against holdover former owners because they were also tenants at sufferance under A.R.S. 12-1173(1) (2003), which then, as now, states there is a forcible detainer when a tenant "at will or by sufferance" refuses to surrender possession. Id. at 558-59, 550 P.2d at 112-13.