§ 2.3 CONFLICT OF LAWS

• Jurisdiction: Arizona

In Aries v. Palmer Johnson, Inc., 153 Ariz. 250, 258, 735 P.2d 1373, 1381 (App. 1987), the court of appeals held the right to recover attorneys' fees under A.R.S. § 12-341.01(A) was a matter of substantive law?a form of damages?and therefore applicable in a multi-state contractual dispute in which Arizona was the state with the most significant contacts. Although other Arizona cases have recognized that fees awarded under the statute are not damages, see Kresock v. Gordon, 239 Ariz. 251, ¶¶ 5-10, 370 P.3d 120, 122-23 (App. 2016) (fees imposed as sanction are not damages for purposes of calculating amount of supersedeas bond); City Ctr. Exec. Plaza, LLC v. Jantzen, 237 Ariz. 37, 41, ¶ 13, 344 P.3d 339, 343 (App. 2015) (award of fees pursuant to A.R.S. § 12-341.01(A) does not...