Hughes v. Jorgenson
In Hughes v. Jorgenson, 203 Ariz. 71, 73, P11, 50 P.3d 821, 823 (2002), a county sheriff participated in some decisions concerning an investigation of possible criminal activities by his own sister. Id. at 72, PP 2-4, 50 P.3d at 822.
The State filed several charges against the sheriff, including a conflict of interest charge under A.R.S. 38-503(B). Id. at P 5.
The issue before the supreme court was the statute's requirement that the public officers have a "pecuniary or proprietary interest" in a decision. Id. at 73, P 8, 50 P.3d at 823.
The sheriff argued that he had no such interest. Id. at P 10.
The supreme court agreed, holding that the "interests involved in this criminal prosecution do not fall within the scope of the conflict of interest statute" and ordering the charges dismissed. Id. at P 21, 50 P.3d at 825.