Cal-Am Properties Inc v. Edais Engineering Inc

Summary

The court held that a design professional who lacks contractual privity with a project owner owes no tort duty to reimburse the owner for purely economic losses caused by negligent professional services. Under Arizona's post-foreseeability duty framework, neither a special relationship, applicable statutes and regulations, nor the Restatement provisions invoked by Cal-Am created a duty on these facts. The court therefore affirmed summary judgment for Edais and the court of appeals' decision.