Richards v. Powercraft Homes, Inc
In Richards v. Powercraft Homes, Inc., 139 Ariz. 242, 244-45, 678 P.2d 427, 429-30 (1984), the Arizona Supreme Court established one exception to the privity requirement, holding that the implied warranty of good workmanship and habitability owed by a homebuilder-vendor to its purchaser can be enforced by a subsequent purchaser who was not in privity of contract with the homebuilder-vendor.
The court reasoned that public policy considerations warranted the exception to the privity requirement in light of the vast differences in construction knowledge possessed by a large-scale homebuilder-vendor and homebuyers, a homebuilder's expectation that homes frequently change hands in our mobile society, and the lack of meaningful difference to any party whether defects are suffered by original or subsequent homeowners. Id. at 245, 678 P.2d at 430.