Robinson v. Kay
In Robinson v. Kay, 225 Ariz. 191,3, 6, 7, 236 P.3d 418, 419, 420 (App. 2010), the Court determined it lacked appellate jurisdiction over a quiet title action when the trial court had resolved a claim under an implied easement theory, but had not resolved another purported claim seeking to establish the same easement using a prescriptive easement theory.
Even in the context of Rule 54, Ariz. R. Civ. P. certification, which allowed the court to direct entry of final judgment as to fewer than all claims, appellants could not appeal the ruling until all easement theories had been resolved because they "supported 'only a single claim for relief.'" Robinson, 225 Ariz. 191,6, 236 P.3d at 420.