In Guerra v. State, 348 P.3d 423 (Ariz. 2015), the Arizona Supreme Court held that law enforcement officers do not have a duty of care to accurately deliver next-of-kin (“NOK”) notifications to a decedent’s family members. The Court concluded that officers do not assume a duty of care to an accident victim’s family by undertaking a NOK notification under either the Restatement (Second) of Torts § 323, or the Restatement (Third) of Torts: Liability for Physical or Emotional Harm § 47.  The Court also concluded that public policy militated against finding a duty of care because imposing a duty would cause officers to delay in making NOK notifications, or deter them altogether, resulting in additional trauma for family members.