State ex rel. Industrial Commission v. Galloway

OPINION

SWANN, Judge.

¶ 1 Patrick J. Galloway and Lois J. Galloway d/b/a Galloway Construction (collectively, “Appellants”) appeal from the superior court’s order overruling their objection to a garnishment levied against them by the Arizona Division of Occupational Safety and Health (“ADOSH”). We hold that a Citation and Notification of Penalty can constitute an enforceable civil penalty within the meaning of A.R.S. § 23-418(J). We further hold that because a civil penalty serves as an enforceable lien for eight years, ADOSH timely brought this garnishment action despite the fact that it filed…