§ 3.7.2.5.2 Abandonment of Issues. As a general matter, arguments presented by appellants in the trial court are deemed to be waived or abandoned on appeal if not expressly presented in the appellate brief. See Belen Loan Investors, L.L.C. v. Bradley, 231 Ariz. 448, 457, ¶ 22, 296 P.3d 984, 993 (App. 2012); Sholes v. Fernando, 228 Ariz. 455, 457 n.1, ¶ 1, 268 P.3d 1112, 1114 n.1 (App. 2012) (court of appeals would not address subissues not argued or supported sufficiently in argument sections of appellants’ brief); Hurd v. Hurd, 223 Ariz. 48, 50 n.3, ¶ 9, 219 P.3d 258, 260 n.3 (App. 2009) (where appellant did not properly raise certain evidentiary rules as issues on appeal and did not address them in his brief’s argument section, court of appeals would not address them). See also § 3.7.2.7.1 (regarding citations to supporting authorities).
An issue is considered abandoned or conceded when not raised in an opening brief or argued on appeal. See Robert Schalkenbach Found. v. Lincoln Found., 208 Ariz. 176, 180, ¶ 17, 91 P.3d 1019, 1023 (App. 2004); Torrez v. Knowlton, 205 Ariz. 550, 552 n.1, ¶ 3, 73 P.3d 1285, 1287 n.1 (App. 2003); Rowland v. Great States Ins. Co., 199 Ariz. 577, 581 n.1, ¶ 6, 20 P.3d 1158, 1162 n.1 (App. 2001). A reference to an appellate argument in a one-sentence footnote without any analysis is insufficient to...
