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Rule 36.Real Party in Interest

Part III. Parties · Last amended January 1, 2022 · Last verified September 4, 2026

In one sentenceRule 36 requires an action to be brought in the name of the real party in interest and names who may act for someone who cannot act for themselves.

Full Text of Rule 36

Text sizeJump to: (a) (b) (c) (d) (e)

(a) Generally. An action must be brought in the name of the real party in interest.
(b) Incapacitated Person or Adult in Need of Protection. A guardian or conservator may bring or defend an action, or otherwise act on behalf of, an incapacitated person or an adult in need of protection.
(c) Minor. A guardian, conservator, or a best interests attorney may bring or defend an action, or otherwise act on behalf of, a minor.
(d) Compensation. The court may allocate between the parties the fees and expenses of the minor's representative under (c) as the court deems appropriate.
(e) Action in the Name of the State for Another's Use. When a state statute so provides, an action for another's use or benefit must be brought in the name of the State of Arizona.
End

Rule History

Added Aug. 30, 2018, effective Jan. 1, 2019. Amended on an emergency basis Aug. 30, 2021, effective Sept. 29, 2021, adopted on a permanent basis effective Jan. 1, 2022.

Plain-English Summary

Rule 36 answers a narrow question: whose name goes on the case.

The general rule

An action must be brought in the name of the real party in interest -- the person whose rights are actually at stake, not a relative, friend or advocate acting in their own name.

When the real party cannot act

Two provisions supply a substitute:

  • For an incapacitated person or an adult in need of protection, a guardian or conservator may bring or defend an action or otherwise act on that person's behalf.
  • For a minor, a guardian, a conservator, or a best interests attorney may do so.

The best interests attorney is the family law addition. Rule 10 governs that appointment, and Rule 36(c) is what gives the appointee authority to act in the minor's name rather than merely to advise the court.

Who pays

Section (d) lets the court allocate the fees and expenses of a minor's representative between the parties as it deems appropriate. The cost of the child's representation is therefore a matter the court divides, not a charge that falls automatically on whoever asked for the appointment.

Actions for the State

Where a state statute so provides, an action for another's use or benefit must be brought in the name of the State of Arizona. That is the mechanism behind Title IV-D support enforcement, which proceeds in the State's name for the benefit of the parent or child owed support.

Frequently Asked Questions

Who can file a case on behalf of a child?

Rule 36(c) allows a guardian, a conservator, or a best interests attorney to bring or defend an action, or otherwise act, on behalf of a minor.

Who pays for a child's representative?

Rule 36(d) lets the court allocate the fees and expenses of the minor's representative between the parties as the court deems appropriate.

Can a guardian act for an adult who cannot manage their own affairs?

Yes. Rule 36(b) allows a guardian or conservator to bring or defend an action, or otherwise act, on behalf of an incapacitated person or an adult in need of protection.

Why is a child support case sometimes captioned in the State's name?

Rule 36(e) provides that when a state statute so provides, an action for another's use or benefit must be brought in the name of the State of Arizona.

What does real party in interest mean here?

Rule 36(a) requires the action to be brought in the name of the person whose rights are at stake. Sections (b) through (e) then identify who may act when that person cannot.

Source & verification. Rule text and Rule History reproduced verbatim from the Arizona Rules of Family Law Procedure as published by the Arizona Supreme Court, current through amendments effective January 1, 2026. Promulgated by the Supreme Court of Arizona (Ariz. Const. art. 6, § 5). Last verified September 4, 2026. · Official text
Also known as: real party in interestguardianconservatorbest interests attorneyacting for a minorincapacitated personState of ArizonaTitle IV-Dadult in need of protection