State of Arizona v. Hon. chambers/henderson

Summary

The court held that a county attorney’s prior representation of a criminal defendant does not create an appearance of impropriety requiring disqualification of the entire county attorney’s office unless the prior and current matters are the same or substantially related, or another basis for prejudice exists. Applying the required multi-factor inquiry, the court found no substantial relationship, no demonstrated use of confidential information, no need for disqualification as a remedy, and no meaningful risk of public suspicion. The court vacated the disqualification order and reinstated the county attorney’s office as the prosecuting agency.