§ 5.5.1 Need for Trial.

• Jurisdiction: Arizona

§ 5.5.1 Need for Trial. A broad reading of one of the earlier state cases on declaratory relief might suggest that trials are not available in such actions. In Skinner v. City of Phoenix, 54 Ariz. 316, 95 P.2d 424 (1939), the court held that a declaratory judgment action lay to test the constitutionality of a statute governing a municipality’s annexation of property, but could not test whether there had been compliance with the statute. The court stated that “[d]eclaratory judgments are primarily to construe the meaning...