Campana v. Ariz. State Land Dep't

In Campana v. Ariz. State Land Dep't, 176 Ariz. 288, 292, 860 P.2d 1341, 1345 (App. 1993), the bid protester argued that no current appraisal had been performed. 176 Ariz, at 292, 860 P.2d at 1345. The Court concluded that "when the Commissioner set the pre-auction value, he did an appraisal by that very act." Id. The protester contended that the Commissioner had "merely concurred" with a prior independent appraisal without conducting the required separate appraisal. Id. The Court determined that when the Commissioner sets the value of land, in effect, he is making an appraisal, even if he relies on prior data. Id. The Court found the process to be a "reasonable rather than random determination." Id. The Court also noted that simply because the petitioner disagreed with the appraised value, such disagreement did not suggest that the required appraisal was ignored. Id.