Hernandez v. State, 203 Ariz. 196

Summary

The Supreme Court of Arizona held that, assuming Arizona Rule of Evidence 408 applies to a statutory notice of claim, the rule does not bar using factual statements from the notice to impeach a party’s credibility. The court reasoned that impeachment is a purpose other than proving liability, invalidity, or amount of a claim, subject to Rules 401, 402, and 403. The court vacated the Court of Appeals’ opinion and affirmed the Superior Court’s judgment for the State.

Holdings

1. Rule 408 does not prohibit admission of evidence from compromise negotiations when it is offered to impeach a party's credibility rather than to prove liability for, invalidity of, or the amount of the claim.
2. Evidence from a notice of claim admitted for impeachment remains subject to Rules 401, 402, and 403, including the requirement of relevance and the prohibition on admission when unfair prejudice substantially outweighs probative value.
3. The trial court properly admitted portions of the notice of claim for impeachment because the State offered them to address inconsistent versions of the facts, not to establish nonliability or disprove the validity or amount of Hernandez's claim.

Questions Presented

1. Whether Rule 408 of the Arizona Rules of Evidence bars admission of factual material in a statutory notice of claim when offered to impeach a party's credibility.
2. Whether, assuming the notice of claim constitutes an offer of compromise under Rule 408, evidence from the notice may be admitted for a purpose other than proving liability, invalidity, or the amount of the claim.

Disposition

vacated