Arizona Supreme Court

Markham v. Cahava

June 17, 2026

Summary

The court held that the improper-conduct requirement applicable to unjust-enrichment claims involving tenant-ordered improvements does not extend to an owner that sought improvements, arranged for them through a third party, and paid no one for the work. Applying the broader unjust-enrichment framework, the court concluded that Markham sufficiently alleged that the Landowners received an uncompensated benefit and that dismissal was improper. The court reversed the superior court, vacated the court of appeals memorandum decision, and remanded for further proceedings.