Delgado v. Manor Care of Tucson AZ, LLC

JUSTICE GOULD,

opinion of the Court:

¶ 1 In this case we are asked to determine what constitutes an actionable claim for abuse of a vulnerable adult under the Adult *311Protective Services Act (APSA), A.R.S. §§ 46-451 through -459. We hold that such a claim requires proof that: (1) a vulnerable adult, (2) has suffered an injury, (3) caused by abuse, (4) from a caregiver. AR.S. §§ 46-451(A)(1)(b), -455(B). In making this determination, we abolish the four-part test for an actionable claim set forth in Estate of McGill ex rel. McGill v. Albrecht, 203 Ariz. 525, 530 ¶ 16, 57 P.3d 384 (2002).

BACKGROUND

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