Cited by

See 15 RABA v. CONNECT, et al. Opinion of the Court Valencia Energy Co. v. Ariz. Dep’t of Revenue, –77 ¶ 35 (1998); ¶ 34 (App. 2008) (recognizing “equitable estoppel is an affirmative defense”).

Valencia Energy Co. v. Ariz. Dep’t of Revenue, ¶ 25 (1998) (noting that “our cases have long recognized the limitations imposed by article III [of the Arizona Constitution] on exercising judicial power in tax matters”); see also Ariz. Sch.

See Valencia Energy Co. v. Ariz. Dep’t of Revenue, ¶ 29 (1998) (noting the “axiom that an administrative agency .

¶18 ¶ 36 (1998), to contend that “the state may not be estopped due to the casual acts, advice, or instructions issued by nonsupervisory employees.” Valencia involved an equitable estoppel claim against the state from acting, not a negligent misrepresentation claim for money damages.

Valencia Energy Co. v. Ariz. Dep’t of Revenue, –77, ¶ 35 (1998).

See Valencia Energy Co. v. Ariz. Dep’t of Revenue, ¶ 2 (1998).

See Code §§ 14-370(a) and 14-400(c); see also Valencia Energy Co. v. Ariz. Dep’t of Revenue, ¶ 55 (1998) (the department can be estopped from collecting taxes if taxpayer proves the department held inconsistent positions).

See Valencia Energy Co. v. Ariz. Dep't of Revenue , , ¶¶ 32-34, (recognizing equitable estoppel rarely applied against government except in cases where "the erroneous advice of the government ...

Comm’n, see also Valencia Energy Co. v. Ariz. Dep’t of Revenue, –77 ¶ 13 MCLAUGHLIN V. JONES (MCLAUGHLIN) Opinion of the Court 35 (1998) (“The three elements of equitable estoppel are traditionally stated as: (1) the party to be estopped commits acts inconsistent with a position it later adopts; (

§ 12-1802(4) even though there was no question as to validity of statute or right of public officers to enforce it; anti-injunction statute inapplicable when public officers exceed their authority or act beyond their power), overruled in part on other grounds by Valencia Energy Co. v. Ariz. Dep’t of Revenue, , , (superior court empowered to enjoin a school board from investigating and censuring a member of the board when neither the state constitution nor applicable statutory scheme expressly or

She sought either the immediate return of her currency or an equal payment because “[m]oney is fungible.” Ariz. Dep’t abrogated on other grounds by Valencia Energy Co. v. Ariz. Dep’t of Revenue, ¶¶ 10 & n.3, 34, & n.3, 1267 (1998).

Nevertheless, in Valencia Energy Co. v. Arizona Dep’t of Revenue, P.2d 1256 (1998), our supreme court acknowledged that in rare situations the government can be equitably estopped from assessing a tax that is legally owed by a taxpayer.

Valencia Energy Co. v. Ariz. Dep’t of Revenue, -77, ¶¶ 35, 37, -68 (1998).

o prevail on a claim for estoppel requires: “‘(1) the party to be estopped commits acts inconsistent with a position it later adopts; (2) reliance by the other party; and (3) injury to the latter resulting from the former’s repudiation of its prior conduct.’” -11, ¶ 21, -05 (App. 2012) (quoting Valencia Energy Co. v. Ariz. Dep’t of Revenue, -77, ¶ 35, - 68 (1998)).

(1) the party to be estopped commits acts inconsistent with a position it later adopts; (2) reliance by the other party; and (3) injury to the latter resulting from the former’s repudiation of its prior conduct.” Valencia Energy Co. v. Ariz. Dep’t of Rev., -68 (1998).

“Estoppel sounds in equity and will therefore not apply to the detriment of the public interest.” Valencia Energy Co. v. Ariz. Dep’t of Revenue, ¶ 32

See Valencia Energy Co. v. Ariz. Dep’t of Revenue, ¶55 , -13 , ¶ ¶ 21-27, -07 (App.2012).

“The three elements of estoppel are: ‘(1) the party to be estopped commits acts inconsistent with a position it later adopts; (2) reliance by the other party; and (3) injury to the latter resulting from the former’s repudiation of its prior conduct.’” -11, ¶ 21, -05 (App. 2012) (quoting Valencia Energy Co. v. Ariz. Dep’t of Revenue, -68 (1998)).

The three elements of equitable estoppel are: “(1) the party to be estopped commits acts inconsistent with a position it later adopts; (2) reliance by the other party; and (3) injury to the latter resulting from the former’s repudiation of its prior conduct.” Valencia Energy Co. v. Ariz. Dep’t of Revenue, -77, ¶ 35, -68 (1998); see Gorman, 230 Ariz. at 510-11, ¶ 21, 287 P.3d at 804-05 (noting the three elements of an equitable estoppel defense).

¶ 31, (estoppel may lie against the government).

ed a narrow exception to the statutory prohibition against injunctive relief when the challenged taxes have been levied without semblance of authority “and resulting injury cannot be adequately provided by proceedings at law.” Crane Co. v. Ariz. State *465 Tax Comm’n, , overruled in part on other grounds by Valencia Energy Co. v. Ariz. Dep’t of Revenue, , see also Santa Fe Trail Transp.

¶21 The three elements of estoppel are: “(1) the party to be estopped commits acts inconsistent with a position it later adopts; (2) reliance by the other party; and (3) injury to the latter resulting from the former’s repudiation of its prior conduct.” Valencia Energy Co. v. Ariz. Dep’t of Revenue, -68 (1998).

violations); cf. City of Tucson v. Clear Channel Outdoor, Inc., ¶¶ 67-68 , (government may be estopped from enforcing zoning ordinance “ ‘only when the public interest will not be unduly damaged and when [estoppel] will not substantially and adversely affect the exercise of governmental powers’ ”), quoting Valencia Energy Co. v. Ariz. Dep’t of Revenue