Contribution Remedy In Arizona

In Arizona, contribution is an equitable remedy that has been recognized by the Arizona courts and legislature in limited circumstances, most notably in the insurance and tort contexts. See: Cal. Cas. Ins. Co. v. Am. Family Mut. Ins. Co., 208 Ariz. 416, 417-18, 422, 1-2, 24, 94 P.3d 616, 617-18, 622 (App. 2004); Mut. Ins. Co. of Ariz. v. Am. Cas. Co. of Reading Pa., 189 Ariz. 22, 26, 938 P.2d 71, 75 (App. 1996); Am. Cont'l Ins. Co. v. Am. Cas. Co. of Reading Pa., 183 Ariz. 301, 302, 903 P.2d 609, 610 (App. 1995); W. Agric. Ins. Co. v. Indus. Indem. Ins. Co., 172 Ariz. 592, 595, 838 P.2d 1353, 1356 (App. 1992); See also A.R.S. 12-2501 to -2509 (2003) (adopting the Uniform Contribution Among Tortfeasors Act). See also Fischer v. Sommer, 160 Ariz. 530, 531, 774 P.2d 834, 835 (App. 1989) (recognizing the right of a former spouse to seek contribution for payment of community debts not allocated by the divorce decree). However, Arizona has not previously addressed contribution as an equitable remedy permitting one dominant tenant to require another dominant tenant to contribute to repair and maintenance of an easement.