Arizona Supreme Court
Stephens v. State
May 22, 2026
Summary
The court held that Stephens failed to state a wrongful institution of civil proceedings claim because prior juvenile-court and appellate adjudications established probable cause for the dependency proceedings, absent allegations that DCS procured those adjudications through fraud, perjury, or comparable corrupt means. Alternatively, even without giving conclusive effect to those adjudications, the complaint did not plausibly allege that DCS lacked an honest and objectively reasonable belief that dependency could be established. The court vacated the court of appeals’ decision and affirmed dismissal under Rule 12(b)(6).