Sparks v. Republic National Life Insurance Co
In Sparks v. Republic National Life Insurance Co., 132 Ariz. 529, 647 P.2d 1127, 1139 (Ariz. 1982), a private cause of action existed under the Unfair Claims Settlement Practices Act ("UCSPA").
In finding a cause of action, the court principally relied on the following statutory language: "the provisions of this article shall not bar any claim against any person who has acquired any monies or property, real or personal, by means of any practice declared to be unlawful by the provisions of this article." Id. at 1138-39.