Heinig v. Hudman
In Heinig v. Hudman, 177 Ariz. 66, 71, 865 P.2d 110, 115 (App. 1993), the Court rejected appellant's argument that a judgment against one party could be converted into a judgment against his wife where it was clear from the record that she never had been a party to the underlying proceeding. 177 Ariz. at 70, 865 P.2d at 114.
The Court was not persuaded by the fact that she had "sat through the arbitration hearing" and "may have assisted in presenting her husband's case." Id.
Rather, the spouse was entitled to "a full opportunity to contest . . . liability" in a subsequent action against her as a named defendant in order to satisfy the strictures of due process. Id. at 71, 865 P.2d at 115.