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A “special order made after final judgment” is appealable only if “the issues raised by the appeal from the order [are] different from those that would arise from an appeal from the underlying judgment.”

¶ 10 (App. 2021) (special orders made after final judgment must “affect ‘the underlying judgment by enforcing it or staying its execution’” (–27 (App. 1995))); ¶ 14 (App. 2011) (an appealable special order “alters the legal rights or responsibilities of the parties” without “need for later court action”).

A party may appeal a final decision under Rule 24.3(c) within 20 days, but that decision must “raise[] issues different from those that could have arisen from an appeal from an underlying judgment,” Jimenez, 188 Ariz. at 345 (–27 (App. 1995)), and affect that judgment, Arvizu, 183 Ariz. at 227.

To constitute such a “special order made after final judgment,” an order (1) must involve different issues than “those that would arise from an appeal from the underlying judgment” and (2) must affect “the underlying judgment by enforcing it or staying its execution.” –27 (App. 1995); ¶ 3 (App. 2000) (quoting Arvizu).

[and] multiple appeals raising the same issues.”

See ARCAP 9(e)(1); –27 (App. 1995) (appeal from post-judgment order must raise issues “different from those 4 REP CUSTOM v. MCBRIDE Decision of the Court that would arise from an appeal from the underlying judgment” for the order to be indepe

To qualify as such, the orders must: (1) raise an issue “different from those that could have been raised on appeal from the underlying judgment,” and (2) “either affect the judgment or relate to its enforcement.” ¶ 9 (2017) (citing Reidy v. O’Malley Lumber Co., -27 (App. 1995)).

See Reidy v. O’Malley Lumber Co., –27 (App. 1995).

§ 12-2101(A)(2), the order “must raise different issues than those that would be raised by appealing the underlying judgment.” ¶ 3 (App. 2000) (–27 (App. 1995)) (emphasis added).

Waste Mgmt., Inc., , a l’uling on a motion to set aside a final default judgment, , and other post-judgment rulings relating to a final judgment, -27 , (“To be appealable, a post-judgment order must fulfill two requirements.

Waste Mgmt., Inc., a ruling on a motion to set aside a final default judgment, and other post-judgment rulings relating to a final judgment, -27 (App. 1995) (“To be appealable, a post-judgment order must fulfill two requirements.

raise different issues than would 4 ADES/BUTKIVICH v. CONTRERAS Jones, J., Dissenting 166, ¶¶ 20-21 (-27 (1995); ¶ 19 (App. 2009); and ¶ 3 (App. 2000)).

§ 13-4033(A)(3); (holding the denial of a motion to modify terms of a defendant’s probation is not an order affecting the substantial rights of the defendant) (-27 (App. 1993), ).

Arizona Revised Statutes (“A.R.S.”) section 12-2101(A)(2) allows appeals from “any special order made after final judgment.”2 However, “not every order following a final judgment is appealable.” (citation omitted).

3 PHILLIPS v. GARCIA Opinion of the Court (App. 2001) (court sua sponte accepted special action jurisdiction after it determined it lacked appellate jurisdiction); (court treated appeal from the trial court’s paternity testing order as a special action and exercised special action jurisdiction).

“[N]ot every order following a final judgment is appealable.”

“[A]n order that is merely ‘preparatory’ to a later *625 proceeding that might affect the judgment or its enforcement is not appealable.” , (citing Lakin v. Watkins Associated Indus., 6 Cal.4th 644, 651-52 , 25 Cal.Rptr.2d 109, 113-114 , -84 (1993)).

-27, -33 (App. 1995); cf. § 12-2101(K)(2) (orders revoking or refusing to 2 revoke prior adjudications of insanity and incompetency are appealable orders).