Barth v. Cochise County
In Barth v. Cochise County, 213 Ariz. 59, 63-64,17, 138 P.3d 1186, 1190-91 (App. 2006), the Court held that notices of claim alleging harassment, retribution and retaliation by an employer served prior to an alleged constructive discharge were not valid because they did not give the employer substantive notice of the potential liability for constructive discharge and a meaningful opportunity to settle the claim.
However, as the court in Barth expressly pointed out, it was not addressing whether a premature notice of claim could be sufficient because the plaintiff had not provided any theory or authority for that argument. Id. at 64 n.5,17, 138 P.3d at 1191 n.1.