Lancaster v. Arizona Board of Regents

In Lancaster v. Arizona Board of Regents, 143 Ariz. 451, 454-55, 457, 694 P.2d 281, 284-85, 287 (App. 1984) the Court held that a legislative enactment requiring the Board of Regents to prepare a report for the legislature on the development of a system of wage and salary equivalency did not provide an implied private right of action. In that case, employees of the University of Arizona brought an action against the Board of Regents seeking a declaratory judgment setting forth their right to lost wages. Id. at 453, 694 P.2d at 283. The Court inferred that the "sole and exclusive purpose" of the legislative enactment was to require the Board of Regents to prepare and submit a report to the legislature, creating a legislative right to receive the report, but not creating a right for those "individuals who might benefit incidentally" from the report. Id. at 457, 694 P.2d at 287. Because the plaintiffs were not members of "the class for whose especial benefit" the enactment was intended, they could not pursue any private rights under it. Id.