Friday, June 12, 2026, the Arizona Court of Appeals issued a decision in Barrera v. Sedona Point LLC.This ruling is good news for landlords and brings everyone back under a single interpretation of the law with regard to eviction actions for nonpayment of rent. Since the CARES Act was passed in 2020, landlords in Arizona have been working to comply with the current interpretation and implementation of the law. Once the nonpayment eviction moratorium expired, landlords were left with a variety of regulations in the CARES Act that continued to effect nonpayment cases until last week. The CARES Act had a provision requiring a thirty day waiting period before a tenant was removed for nonpayment of rent in an eviction action if the property had federal assistance. This included properties with federally backed mortgages through the VA, Fannie Mae, Freddie Mac and more. Pima County ultimately adopted an interpretation of the law that required landlords to provide a notice a thirty day notice before they could file an eviction action for nonpayment of rent if the residence met the federally backed requirements under the CARES Act. Other parts of the state interpreted the CARES Act requirements to simply require a 30 day waiting period between the providing of the nonpayment notice and the execution of a writ of restitution. This disjointed application lead to confusion and delays that harmed landlords.
The Barrera ruling states the CARES Act has expired. This brings all landlords and tenants back to the Arizona revised statutes as our guide for eviction actions. Landlords are no longer required to provide a 5/30 or 7/30 day notice for nonpayment of rent in Pima County. Landlords across the state are no longer required to wait 30 days after providing a notice of nonpayment before applying for a writ of restitution under a judgment. Landlords and Property Managers may discard their 5/30 and 7/30 day forms and go back to the standard nonpayment forms. We will no longer be asking if your property has a federally backed mortgage.
Should there be any changes we will of course post an update. Thank you for your patience as we update forms available through the Client Corner. As always, please let us know if you have any questions.