Verner v. Redman
In Verner v. Redman, 77 Ariz. 310, 271 P.2d 468 (1954) the Arizona Supreme Court wrote that "a private individual must both allege and prove special damages peculiar to himself in order to entitle him to maintain a cause of action of this character." Id. at 312, 271 P.2d at 469.
The cause of action in Verner was a suit by neighbors to enjoin the construction of a gas station in a residential area. Id. at 311, 271 P.2d at 468.
The court did not take judicial notice because the evidence was insufficient to establish that the complaining individuals owned "adjoining" property. Id. at 314, 271 P.2d at 470.
The court was not willing to commit . . . to the rule that it can take judicial notice of special damages to property . . . unless the evidence definitely shows it to be adjacent thereto or in such proximity thereof as to make the fact of damages so certain and undisputable that evidence will not be received to refute it. Id.