Blauvelt v. County of Maricopa
In Blauvelt v. County of Maricopa, 160 Ariz. 77, 770 P.2d 381 (App. 1988), the Court addressed whether delivery of a notice of claim to the Maricopa County Recorder constituted service on the "recording officer" named in Rule 4.1(i).
In deciding that such service was insufficient, the court stated that a county's board of supervisors is the entity empowered to direct and compromise all lawsuits involving that county. Id. at 79, 770 P.2d at 383 (citing A.R.S. 11-251(14)).
For this reason, the court held that a county's board of supervisors constitutes that county's "chief executive officer" for purposes of Rule 4.1(i). Id.
After examining predecessor statutes governing service of process on counties, and noting that an elected county recorder does not serve the board of supervisors, the court concluded that the "recording officer" named in Rule 4.1(i) refers to the recording officer of the board of supervisors rather than the county recorder. Id. at 79-80, 770 P.2d at 383-84.
Thus, a party intending to submit a claim to a county must serve it on the board of supervisors or the board's secretary, clerk, or recording officer. Id. at 80, 770 P.2d at 384.