Simms v. Arizona Racing Commission

Summary

The court held that the 2021 amendments to A.R.S. § 12-910(F) retained substantial-evidence review while eliminating deference to agency factfinding in proceedings brought by or against a regulated party. The superior court must independently determine disputed facts, law, and mixed questions, then decide whether the agency’s final action satisfies the statutory grounds for affirmance. Appellate courts may not independently redetermine those facts; they defer to supported superior-court findings while independently reviewing the legal sufficiency of the agency action. The court vacated the court of appeals’ judgment and remanded for the superior court to apply this framework.