Arizona Rule Criminal Procedure Rule 26.2(B)
Maricopa Cnty. Juv. Action No. JS-8441, 174 Ariz. 341, 849 P.2d 1371 (1992), the issue was whether the father's notice of appeal had been timely filed.
The minute entry order father appealed from had the date "10-18-90" stamped in the upper left hand corner. Elsewhere on the minute entry, the word "Received" was stamped on the document with a corresponding date of October 25, 1990, and the word "Processed" was also stamped on the document with a date of October 25, 1990.
Under the facts of the case, if the October 18 date controlled, the notice of appeal was untimely, but if the October 25 date was the operative date, the notice was timely.
After describing Maricopa County's "confusing" practice regarding minute entries, and the frustrations this confusion had created when trying to calculate time periods, the supreme court held that "the last official date" on the Maricopa County minute entry would be used as the filing date.
The court stated:
Civil judgments which are not minute entries are file stamped and, thus, there is no confusion about the date from which the appeal lies. But judgments which are minute entries are infected with the same confusion which infects the juvenile minute entry in this case.
In the best of all worlds, all judgments or orders from which appeals lie in any kind of case would be clear and free of confusion. Examples are the non-minute entry civil judgment with a file stamp date and, in criminal cases, the oral pronouncement of judgment at the time of sentencing under Rule 26.2(b), Ariz.R.Crim.P. Id., 174 Ariz. at 342-43, 849 P.2d at 1372-73.