§ 5.6.2 Supplemental Relief.

• Jurisdiction: Arizona

§ 5.6.2 Supplemental Relief. A.R.S. § 12-1838 authorizes the court to grant further relief based on a declaratory judgment “whenever necessary or proper.” It provides that the application for such relief shall be by complaint or appropriate pleading to a court having jurisdiction to grant it. If the court finds that the application is sufficient it shall, “on reasonable notice, require any adverse party whose rights have been adjudicated by the declaratory judgment or decree, to show cause why further relief should not be granted forthwith.” Id.

Supplemental relief has taken many forms in the Arizona courts. In Adams v. Bear,87 Ariz....