Arizona Supreme Court
Al Carranza, a Married Man, Plaintiff/cross-Defendant/appellant v. Mario A. Madrigal, an Individual; Martha C…
July 22, 2015237 Ariz. 512
Summary
The court held that substitution of a real party in interest under Rule 17(a) must be pursued through a Rule 15(a) motion to amend. Because Carranza did not properly seek amendment and, in any event, the proposed substitution followed deliberate delay and would prejudice the opposing parties, the superior court acted within its discretion in denying substitution. The court affirmed the superior court's order and vacated the specified portions of the court of appeals' decision.