Jones v. Roach

In Jones v. Roach, 118 Ariz. 146, 150, 575 P.2d 345, 349 (App. 1977), a Colorado judgment was filed in Arizona for enforcement under the UEFJA. Id. at 148, 575 P.2d at 347. The judgment-debtor filed a motion in Arizona invoking Arizona Rule of Civil Procedure 60(c) ("Rule 60(c)"), seeking to prohibit enforcement of the Colorado judgment in Arizona on the grounds of excusable neglect. Id.; see Az. R. Civ. P. 60(c) (allowing relief from a judgment on the grounds of mistake, inadvertence, surprise or excusable neglect). The Jones court concluded that the UEFJA did not allow an Arizona court to entertain such a motion for relief. 118 Ariz. at 150, 575 P.2d at 349. It reasoned that although comparable Rule 60(c) proceedings might still be instituted in Colorado, the judgment must be afforded full faith and credit in Arizona. Id. at 150-51, 575 P.2d at 349-50. The Jones court further opined that the adoption of the UEFJA did not create a substantive right in Arizona to modify the Colorado judgment and that unless and until such a modification might be achieved in Colorado, the judgment must be afforded finality in Arizona. Id. at 150, 575 P.2d at 349.