Wendling v. Southwest Savings & Loan Association
In Wendling v. Southwest Savings & Loan Association, 143 Ariz. 599, 694 P.2d 1213 (App. 1984), the court held it had jurisdiction only to review the issues raised in a Rule 59 motion when the notice of appeal referenced only that motion. Id. at 601, 694 P.2d at 1215.
Significantly, the Rule 59 motion in that case was based "solely on the grounds of newly discovered evidence" and did not otherwise allege a specific error with respect to the underlying judgment. Id.