Hoffman v. Greenberg
In Hoffman v. Greenberg, 159 Ariz. 377, 767 P.2d 725 (App. 1988) the Court held that an appraiser hired by the seller of parcels of vacant land owed no duty to the third-party purchaser of the property. 159 Ariz. at 380, 767 P.2d at 728.
The seller had refused to inform the appraiser how he intended to use his report, and the report itself stated "the function of this report is to aid our client" and it "may not be used for any purpose other than its intended use." Id. at 378-79, 767 P.2d at 726-27 (second alteration in Hoffman).
Although it may have been reasonably foreseeable that the owner might show an appraisal to prospective buyers, we declined to measure liability by the reasonable-foreseeability standard. Id. at 379-80, 767 P.2d at 727-28.
Hoffman v. Greenberg, addressed the duty owed by an appraiser hired by a property owner to appraise vacant land. At the time the owner hired the appraiser, he refused to disclose to him how he intended to use the appraisal. Hoffman, 159 Ariz. at 378-79, 767 P.2d at 726-27.
The owner later showed the appraisal to an investor who allegedly relied on it to his detriment in deciding to purchase. Id. at 378, 767 P.2d at 726.
Citing section 552, the court held the purchaser was not among the class of persons entitled to rely on the appraisal. Id. at 380, 767 P.2d at 728.