Cited by

¶ 27 (App. 2010); see Poleo, 143 Ariz. at 133 (finding a willful and bad faith failure to produce documents sufficient to impose a default); see also Green, 221 Ariz. at 154, ¶ 45 (identifying other factors courts consider).

We review a superior court’s orders striking pleadings for an abuse of discretion; however, a court’s discretion when striking pleadings or entering default judgments “is more limited than when it employs lesser sanctions.” ¶ 27 (App. 2010) (internal quotation omitted) ( ¶ 11 (App. 2008)).

DISCUSSION ¶18 We review a superior court’s award of Rule 37 sanctions for an abuse of discretion, ¶ 24 2 Marks lodged a criminal complaint against the third arbitrator for engaging in “fraudulent schemes.” 5 MARKS v. DIXON Decision of the Court (App. 2010), and legal error constitutes an abuse of discret

“Trial judges are better able than appellate courts to decide if a disclosure violation has occurred in the context of a given case and the practical effect of any non-disclosure.” Id.; –22, ¶ 34 (App. 2010) (stating the appellate court will not disturb the trial court’s decision to award attorneys’ fees as a sanction for discovery violations absent a clear 7Mother explains that she did not file a motion because she was not seeking affirmative relief, but the record belies this explanation.

¶ 31, (holding that a court must find the party personally at fault and consider lesser sanctions before imposing the sanction of entering a default judgment for discovery violations).

Ltd. P'ship, ¶ 5 (App. 1999), a "willful disregard of discovery obligations" may be a "valid basis" for entry of judgment in favor of the moving party, ¶ 27 (App. 2010).

–22, ¶ 34 (App. 2010); see also Ariz. R. Fam.

“If the verdict is supported by adequate evidence, it will not be disturbed, and the greatest possible discretion is in the hands of the trial judge.” ¶ 41

The award and amount of attorney fees is a matter “peculiarly within the discretion of [the] trial court.” ¶ 47 (App. 2010) (quoting Harris v. Reserve Life Ins.

-20, ¶ 27, -73 (App. 2010).

But when a court imposes severe sanctions such as dismissal, striking a pleading, or entering a default judgment, “its discretion ‘is more limited than when it employs lesser sanctions.’” see Groat, 180 Ariz. at 346, 884 P.2d at 232; Poleo v. Grandview Equities, Ltd.

*362 at 143, ¶ 34, 163 P.3d at 1093 (Espinosa, J., dissenting) (“[T]he majority’s nominal damages position merely begs the question why, absent some statutory guidance, an award of $1 would be an adequate, if demeaning, award but not zero.”); , 122 n. 5, ¶ 38, , 275 n. 5 (App.2010) (stating that nominal damages are awarded to vindicate rights).