Deer Valley Unified School District No. 97 v. Houser

In Deer Valley Unified School District No. 97 v. Houser, 214 Ariz. 293, 152 P.3d 490 (2007), the supreme court addressed whether the statement of the amount for which the claim could be settled in the notice of claim filed in that case was sufficiently specific. See 214 Ariz. 293, P 10, 152 P.3d at 493. The notice of claim in that case identified several claim amounts but "repeatedly used qualifying language" such as "'approximately,'" "'or more,'" and "'no less than'" in describing those amounts. Id. The court determined that such qualifying language made "it impossible to ascertain the precise amount for which the defendant could have settled the claim." Id. Thus, the court concluded, "in light of the substantial variation in potential value and the absence of any clear aggregate claim amount in the notice of claim, the amounts identified . . . cannot be considered 'specific.'" Id. P 11.