Landi v. Arkules
In Landi v. Arkules, 172 Ariz. 126, 835 P.2d 458 (App. 1992), the defendants claimed their failure to obtain a statutorily required private investigator's license did not render their "heir finder" agreement unenforceable. Relying on the general principle that "an agreement is unenforceable if the acts to be performed would be illegal or violate public policy," id. at 133, 835 P.2d at 465.
The Court held that "the regulation of private investigators is so infused with important public policy considerations that a contract to perform investigations is, in the absence of a license, unenforceable." Id. at 135, 835 P.2d at 467.