Gulf Homes, Inc. v. Beron
In Gulf Homes, Inc. v. Beron, 141 Ariz. 624 , 688 P.2d 632 (1984), the Court upheld dismissal as a sanction when a party had acted in "'flagrant bad faith'" by refusing to respond to questions during a deposition. 141 Ariz. at 629, 688 P.2d at 637.
The court noted that the questions asked "were material to the claims" and that the party's refusal to answer injected delay and "exacerbated the costs inherent in the litigation." Id.