Creasy v. Coxon
In Creasy v. Coxon, 156 Ariz. 145, 147, 750 P.2d 903, 905 (App. 1987) the public entity, a state college, admitted that it had received the plaintiff's notice of claim. Given that admission, we held that the plaintiff had met his burden to show that delivery was actually made, even though such delivery was accomplished by mail. Id. at 148, 750 P.2d at 906.
However, we cautioned that "in cases where a public entity or public employee challenges the notice given, the claimant must show that delivery was actually made." Id.
Creasy was decided under the previous version of A.R.S. 12-821.01(A), which stated, in relevant part, "persons who have claims against a public entity or public employee shall file such claims in the same manner as that prescribed in the Arizona Rules of Civil Procedure, Rule 4(d)."