§ 3.3.1.3 Postjudgment Orders.

• Jurisdiction: Arizona

§ 3.3.1.3 Postjudgment Orders. Another major category of judgments and orders appealable under A.R.S. § 12-2101 is postjudgment orders such as those granting or denying a motion for a new trial, or setting aside or refusing to vacate a default judgment. See Bateman v. McDonald, 94 Ariz. 327, 329, 385 P.2d 208, 210 (1963). See also §§ 3.3.1.8, 3.3.1.12.1.8. The court of appeals has recognized its jurisdiction over an appeal from a denial of a Rule 59(a) motion for a new trial contesting the denial of a Rule 60(c) motion. See Tripati v. Forwith, 223 Ariz. 81, 85, ¶ 17, 219 P.3d 291, 295 (App. 2009).

An appellate court also has jurisdiction over a special order made after final judgment pursuant to A.R.S. § 12-2101(C). A special order in this category must raise different issues than those raised by appealing the final judgment, affect the underlying judgment, relate to its enforcement or stay its execution, and not be “merely preparatory” to a later proceeding that might affect the judgment or its...