Case Date: 08/17/2021Case Number: 1 CA-CV 19-0350Question Presented: Whether A.R.S. § 12-2605, which generally bars a healthcare provider’s apologetic statements as evidence of liability or an admission against interest in a civil action, violates the Arizona Constitution’s provisions relating to separation of powers, special laws, or privileges and immunities. Decision: The law does not infringe on constitutional separation of powers (Ariz. Const. art. III), is not an unconstitutional special law (Ariz. Const. art. IV, pt. 2, § 19), and does not violate the privileges and immunities clause (Ariz. Const. art. II, § 13). Judge Position: Joined in the 3/0 decision.