Deer Valley Unified Sch. Dist. No. 97 v. Houser

In Deer Valley Unified Sch. Dist. No. 97 v. Houser, 214 Ariz. 293, P 6, 152 P.3d 490, 492 (2007), the Arizona Supreme Court addressed the sufficiency of a notice of claim filed in an employment case involving a wrongful termination claim against a school district. 214 Ariz. 293, PP 1-2, 152 P.3d at 491. In that case, the plaintiff had sent a "'claim letter'" to the district, alleging that she had lost her salary and anticipated raises and also had sustained damages "no less than" certain specified amounts for emotional distress and for harm to "her reputation of employment." Id. PP 2-3. The court concluded that, "by failing to state a specific amount that she would accept to settle her claims, the plaintiff failed to comply with that statutory requirement." Id. P 11. Importantly, the court in Deer Valley addressed only the limited issue of whether the claimant's notice of claim included a "specific sum," as 12-821.01(A) requires. Id. n. 3. The court expressly declined to reach the question of whether the notice "failed to provide facts supporting the amount claimed." Deer Valley, 214 Ariz. 293, n.3, 152 P.3d at 494 n.3. The court noted in dictum, however, that "the claim letter did not provide any facts supporting the claimed amounts for emotional distress and for damages to the claimant's reputation." Id.