Piner v. Superior Court
In Piner v. Superior Court, 192 Ariz. 182, 962 P.2d 909 (1998), the Arizona Supreme Court considered the status of the single injury rule in light of the legislature's abolition of joint and several liability.
The court held that "the present version of UCATA has left intact the rule of indivisible injury, relieving the plaintiff of apportioning damage according to causal contribution." Id. at 188, P 26, 962 P.2d at 915.
The court noted that this rule applies to both multiple causation and successive injury cases:
"Like our predecessors in Holtz, we see no reason to employ a different rule if the injuries occur at once, five minutes apart or, as in the present case, several hours apart.
The operative fact is simply that the conduct of each defendant was a cause and the result is indivisible damage." Id. at 189, P 27, 962 P.2d at 916.