Dunlap v. Jimmy GMC of Tucson, Inc
In Dunlap v. Jimmy GMC of Tucson, Inc., 136 Ariz. 338, 666 P.2d 83 (App. 1983), the Court noted that the defendant "not having asked for special verdicts . . . will not be heard to challenge the validity of the general verdict, the jury having been presented with ample evidence to sustain the award of damages on at least [one] count." Id. at 341-42, 666 P.2d at 86-87.
The Court note that, in Dunlap, the Court placed on defense counsel "the burden of requesting special verdicts after a motion for a directed verdict has been denied." Id. at 341, 666 P.2d at 86.