JTF Aviation Holdings, Inc. v. CliftonLarsonAllen LLPAnnotate this Case
The Supreme Court held that the court of appeals erred by concluding that a contractual limitations provision can preclude nonparties to the contract from asserting tort claims that do not arise out of the contractual relationship.
In affirming the trial court's summary judgment, the court of appeals relied upon the "closely related party doctrine," which looks to the relationship between a nonparty and parties to the agreement, as well as the relationship between a nonparty and the agreement itself. Specifically, the court of appeals concluded that the nonparty was so "closely related" to the contract or its signatories that enforcement of the contract terms was "foreseeable." However, no Arizona court had previously adopted the closely related party doctrine to impose a contractual limitations provision on a nonparty. The Supreme Court reversed, holding that the court of appeals erred in binding the nonparty to a contractual limitations provision based on the closely related party doctrine.