Christian, Dichter & Sluga

Christian, Dichter & Sluga Welcomes Associate Attorney Brynn Toliver to Phoenix Litigation Team

Paul Manley — Fri, 09 Oct 2026 07:00:26 +0000

Christian, Dichter & Sluga, P.C. (CDS) is pleased to welcome Brynn Toliver as an Associate Attorney in the firm’s Phoenix office. Brynn joins the firm’s civil litigation practice, bringing courtroom experience, a background in criminal defense, and a commitment to thoughtful, strategic advocacy.

Brynn’s addition strengthens CDS’s litigation team as the firm continues serving clients in Arizona and throughout the Southwest in complex civil litigation, insurance coverage disputes, insurance litigation, and related legal matters.

A Foundation Built on Courtroom Experience

Before joining Christian, Dichter & Sluga, Brynn practiced criminal defense in Arizona, gaining hands-on experience with hearings, trials, motion practice, settlement conferences, and case management.

Her professional background also includes experience with the Maricopa County Office of the Public Defender, Arizona Justice Project, Maricopa County Superior Court, and private criminal defense firms.

These experiences have provided Brynn with an understanding of litigation from multiple perspectives, helping shape her approach to legal research, case preparation, persuasive writing, and courtroom advocacy.

At CDS, Brynn will apply that foundation to her growing civil litigation practice, working alongside the firm’s attorneys on matters involving insurance litigation, insurance coverage, and other disputes.

An Arizona State University Graduate Committed to Advocacy

Brynn earned her Juris Doctor from the Sandra Day O’Connor College of Law at Arizona State University, where she received a Trial Advocacy Certificate and Pro Bono Distinction.

While attending ASU Law, Brynn served on the Executive Board of the school’s Trial Team and participated in its Public Defender Clinic, representing clients as a certified limited practice student.

Her commitment to developing strong advocates continues outside the office. Brynn serves as a coach for Sun Devil Mock Trial, helping aspiring attorneys strengthen their courtroom presentation, case strategy, and trial advocacy skills.

Before law school, Brynn graduated magna cum laude from Boise State University with a Bachelor of Science in Criminal Justice, a minor in Political Science, and a certificate in Dispute Resolution.

Strengthening Civil Litigation Representation in Phoenix

Christian, Dichter & Sluga has established a longstanding presence in Arizona’s legal community, representing clients in insurance-related disputes, commercial litigation, and other complex civil matters.

Brynn’s addition reflects the firm’s continued investment in developing litigation talent and maintaining the resources needed to provide responsive, effective representation.

Her approach emphasizes preparation, organization, collaboration, and clear communication – qualities that complement the firm’s commitment to delivering practical legal solutions.

Get to Know Brynn Toliver

Beyond her legal practice, Brynn enjoys reading, discovering new restaurants with friends, and helping the next generation of trial advocates develop their skills.

We look forward to the perspective, energy, and experience Brynn brings to Christian, Dichter & Sluga.

Learn more about Brynn’s professional background, education, and practice areas by visiting her attorney biography.

About Christian, Dichter & Sluga

Christian, Dichter & Sluga is a nationally recognized insurance and litigation law firm providing sophisticated legal solutions throughout Arizona, Nevada, and New Mexico. For nearly 50 years, our attorneys have represented insurers, businesses, and organizations in complex coverage disputes, bad faith matters, litigation, and aviation-related claims. What sets CDS apart is the combination of deep courtroom experience, peer-recognized legal talent, and a collaborative approach that delivers the resources of a larger firm with the responsiveness and personal attention clients value. We don’t just know the law – we know the communities, courts, and industries we serve, allowing us to provide strategic counsel and outstanding results when our clients need it most.

The purpose of this publication is to provide readers with information on current topics of general interest and nothing herein shall be construed to create, offer, or memorialize the existence of an attorney-client relationship. The content should not be considered legal advice or opinion, because it may not apply to the specific facts of a particular matter. As guidance in areas is constantly changing and evolving, you should consider checking for updated guidance, or consult with legal counsel, before making any decisions.

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CDS Sponsors Arizona Women Lawyers Association 47th Annual Convention

Paul Manley — Wed, 07 Oct 2026 00:01:58 +0000

Christian, Dichter & Sluga, P.C. (CDS) is proud to sponsor the Arizona Women Lawyers Association (AWLA) 47th Annual Convention, continuing our firm’s longstanding commitment to supporting women in Arizona’s legal community.

The 2026 convention, themed “Celebrating Women, Steering the Future of Law,” will take place October 16 in Phoenix and bring together attorneys, judges, legal professionals, law school faculty and students, and members of Arizona’s legal community for professional development, continuing legal education, networking, and recognition of women making an impact on the profession. AWLA lists the convention as one of its statewide events.

Supporting Women in Arizona’s Legal Community

For CDS, supporting AWLA’s mission has special significance.

As a WBENC-certified women-owned law firm, we believe in creating opportunities for women to lead, develop professionally, build meaningful relationships, and shape the future of the legal profession. CDS is also a member of the National Association of Minority and Women Owned Law Firms (NAMWOLF), and our commitment to the advancement of women extends beyond the practice of law and into the communities we serve.

Our relationship with AWLA is not new. In 2020, Christian, Dichter & Sluga received AWLA’s All in for Women Award, recognizing the firm’s efforts to further AWLA’s mission and support the professional and personal development of women.

Today, women continue to hold key leadership roles at CDS, including shareholders Gena L. Sluga and Amanda J. Taylor, as our attorneys serve clients in insurance coverage, insurance defense, bad faith, commercial litigation, civil appeals, criminal defense, and other complex matters throughout the Southwest.

“As a women-owned law firm, supporting organizations that create opportunities for women attorneys to connect, lead, and advance is especially meaningful to us,” said Amanda J. Taylor, Shareholder at Christian, Dichter & Sluga. “AWLA has made a lasting impact on Arizona’s legal community, and we are pleased to support its 47th Annual Convention and continued work on behalf of women in the profession.”

CDS is proud to stand alongside AWLA and fellow members of the Arizona legal community in celebrating the accomplishments of women lawyers and supporting the next generation of women leaders in law.

We look forward to the 47th Annual Arizona Women Lawyers Association Convention and another opportunity to celebrate the women helping steer the future of law in Arizona.

About Christian, Dichter & Sluga

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Amanda J. Taylor Admitted to the Federation of Defense & Corporate Counsel (FDCC)

Paul Manley — Mon, 05 Oct 2026 21:18:13 +0000

Christian, Dichter & Sluga, P.C. is pleased to announce that Shareholder Amanda J. Taylor has been accepted for membership in the Federation of Defense & Corporate Counsel (FDCC), an international organization of peer-reviewed leaders in the civil defense, corporate legal, and insurance industries.

Amanda is a Phoenix insurance attorney whose practice focuses on insurance coverage, bad faith litigation, and civil appeals. Licensed in Arizona, Illinois, and New Mexico, she represents insurers and other clients in complex insurance and civil litigation matters.

The Federation of Defense & Corporate Counsel (FDCC) brings together vetted defense counsel, corporate counsel, insurance industry executives, and other legal professionals who have achieved professional distinction. The organization is dedicated to advancing integrity and civility within the legal profession, professional education, civil justice, and collaboration among its members. The Federation

Amanda’s admission to the FDCC reflects her experience and reputation within the insurance coverage and litigation communities and further strengthens Christian, Dichter & Sluga’s relationships with leading defense attorneys, corporate counsel, and insurance professionals across the country.

Please join us in congratulating Amanda on this well-deserved professional distinction and her admission to the FDCC.

About Christian, Dichter & Sluga

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Christian, Dichter & Sluga Secures Arizona Supreme Court Victory in Aller v. State

Paul Manley — Thu, 03 Sep 2026 08:40:53 +0000

Christian, Dichter & Sluga attorney Nathan Andrews secured an important victory before the Arizona Supreme Court in Aller v. State, CV-25-0176-PR.

In its August 24, 2026 opinion, the Court clarified when a former criminal defendant may use grand jury transcripts in a subsequent civil action arising from the prosecution. The Court reaffirmed that a party must demonstrate a “particularized need” before using grand jury materials, while recognizing that those transcripts may be uniquely important in malicious prosecution cases because they reveal the evidence and legal theories presented to the grand jury.

The Court also established a new procedural framework for former defendants seeking to use grand jury transcripts lawfully in their possession, providing important guidance for future malicious prosecution claims in Arizona.

Because Arizona law makes it a class one misdemeanor to knowingly disclose the nature or substance of grand jury testimony under A.R.S. § 13-2812, even former defendants in lawful possession of grand jury transcripts that resulted in an indictment against them cannot automatically use those transcripts in a subsequent civil proceeding. Instead, they must seek leave of court to avoid a violation of § 13-2812. Arizona courts have long determined whether disclosure is “in furtherance of justice,” as now required by statute, by applying the “particularized need” framework established in State ex rel. Ronan v. Superior Court, 95 Ariz. 319 (1964). Until recently, however, the “particularized need” cases in Arizona dealt with the disclosure of grand jury transcripts to those who could not otherwise access them. See Ronan, 95 Ariz. 319; see also State v. Bergin, 256 Ariz. 516 (App. 2023).

That changed in 2025 when Mr. Aller and Incito Schools, also represented by our firm, each brought special actions to challenge the denial of their requests to use their respective grand jury transcripts, already in their possession, in civil lawsuits for malicious prosecution after successfully resolving the underlying cases. The Arizona Court of Appeals denied Mr. Aller’s special action, but a different panel of that Court granted the other special action in Incito Schools v. State, 261 Ariz. 72 (App. 2025). The Court of Appeals in Incito Schools addressed the “particularized need” framework of Ronan in this new context. Analyzing the stark differences between the policy concerns posed by a criminal defendant in an on-going criminal case without access to a particular transcript and a former defendant who has been exonerated and who already possesses the given transcript, the Court of Appeals noted significant differences. In Aller, the Supreme Court observed the similarities with Incito Schools and adopted many of the same conclusions about the diminished societal interest in grand jury secrecy under such circumstances. Aller, ¶¶ 39–47. The Supreme Court did, however, note that society’s interest in grand jury secrecy was not “altogether eliminated” Aller, ¶48.

The Supreme Court went on to observe the grand jury secrecy “is not meant to shield a witness who testified falsely from civil accountability for that testimony.” Aller, ¶ 49. Thus, former defendants seeking to vindicate their malicious prosecution claims should not be flatly denied their day in court under the guise of grand jury secrecy. The Court specifically noted that preventing the use of grand jury transcripts would “foreclose an injured party’s ability to prove the elements of his claim” where “the claimed injury flows from a deliberately false and fabricated presentation of evidence and the law to the grand jury[.]” Aller, ¶ 49. This concern suggests that Arizona’s malicious prosecution jurisprudence is continuing to evolve.

The Arizona Supreme Court also provided a new procedural framework for cases where a former defendant seeks to use grand jury transcripts in their lawful possession in a separate civil action. Aller, ¶ 51. Under the new framework, a former defendant should file a motion with the superior court asserting a good faith belief that he has a particularized need to use the transcript which outweighs societal interests in grand jury secrecy. Aller, ¶ 52. With that motion, a former defendant is also directed to file the grand jury transcript under seal and identify which portions of the transcript he seeks to use in the civil action. Id. The Court went on to advise that in cases where a former defendant has already filed a civil action in superior court, the motion and sealed transcript should be filed with the judge presiding over the civil action. Aller, ¶ 53. In adopting this new procedure for former defendants already in possession of their transcripts, the Court rejected the old two-step process that required filing with the presiding judge of the court that supervised the grand jury activities. Aller, ¶ 53.

The Court also slightly modified the procedural mechanism proposed by the Court of Appeals in Incito Schools for cases involving the use of lawfully possessed state grand jury transcripts in federal civil actions. Aller, ¶ 57. Recognizing that federal and state law “substantively differ” with respect to the availability and use of grand jury transcripts, the Arizona Supreme Court held that Arizona’s superior courts must decide “whether a ‘particularized need’ for the use of grand jury transcripts outweighs the societal interests in secrecy” in such cases for the consistent application of Arizona law.

The decision along with the earlier Incito Schools decision that was liberally cited by the Supreme Court in Aller provides meaningful guidance for future malicious prosecution cases in Arizona. The Court confirmed that exonerated defendants may use grand jury transcripts lawfully in their possession to establish that they were maliciously prosecuted, provided the proper procedure is followed. The opinion also recognizes the continued viability of common-law malicious prosecution claims and makes clear that grand jury secrecy should not be used to shield deliberately false testimony from civil accountability.

Nathan Andrews and Steve Dichter represented the clients in the Arizona Supreme Court and, in Incito Schools, in the Court of Appeals proceedings, with Nathan Andrews arguing before the Supreme Court.

Read the entire opinion here.

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7 Christian Dichter & Sluga Attorneys Recognized by Best Lawyers

Paul Manley — Thu, 20 Aug 2026 04:00:30 +0000

Christian, Dichter & Sluga, P.C. is proud to announce that seven of the firm’s attorneys have been recognized in the 2027 editions of The Best Lawyers in America® and Best Lawyers: Ones to Watch® in America.

Five CDS attorneys were selected for inclusion in The Best Lawyers in America®, with recognition spanning insurance law, commercial litigation, appellate practice, white-collar criminal defense, and other litigation practices. Two additional attorneys were recognized in Best Lawyers: Ones to Watch® in America, including Nathan Andrews, who received the recognition for the first time this edition.

2027 The Best Lawyers in America

Amanda J. Taylor
Insurance Law · Litigation – Insurance

Douglas L. Christian
Commercial Litigation · Insurance Law · Personal Injury Litigation – Defendants

Gena L. Sluga
Appellate Practice · Commercial Litigation · Insurance Law · Litigation – Insurance

Jeffrey O. Hutchins
Insurance Law · Litigation – Insurance

Stephen M. Dichter
Commercial Litigation · Criminal Defense: White-Collar · Litigation – Banking and Finance · Litigation – Securities

2027 Best Lawyers: Ones to Watch in America

Kara M. Luebbering
Insurance Law · Personal Injury Litigation – Defendants

Nathan R. Andrews
Insurance Law
First-time Best Lawyers: Ones to Watch® honoree

About the Recognition

Best Lawyers recognition is based on a peer-review process designed to capture the consensus opinion of leading lawyers regarding the professional abilities of their colleagues within the same geographical and legal practice areas. Best Lawyers: Ones to Watch® in America recognizes attorneys earlier in their careers for outstanding professional excellence in private practice.

Christian Dichter & Sluga congratulates all seven attorneys on this recognition and celebrates the professionalism, experience, and commitment to client service they bring to the firm and its clients every day.

About Christian, Dichter & Sluga

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Arizona Supreme Court settles key UM/UIM stacking dispute with important implications for insurers and policyholders

Paul Manley — Wed, 08 Jul 2026 13:20:39 +0000

By: Nathan Andrews

On July 6, 2026, the Arizona Supreme Court held that multiple individuals who jointly purchase multiple insurance policies from the same insurer constitute “one insured” for the purposes of the anti-stacking provisions of A.R.S. § 20-259.01(H). Thus, an insurance company may prohibit a claimant from stacking multiple policies jointly purchased by multiple individuals from the same insurer.

Arizona’s Uninsured/Underinsured Motorist Act (“UM / UIM”) allows an individual covered by more than one automobile insurance policy to collect benefits from multiple policies, i.e. “stack” the UM / UIM benefits unless the insurer strictly complies with the terms of A.R.S. § 20-259.01(H).[1] In 2023, the Arizona Supreme Court held that insurers seeking to prevent the stacking of UIM coverages under a single multi-vehicle insurance policy can only do so by following the terms of A.R.S. § 20-259.01(H). Franklin v. CSAA General Insurance Co.,255 Ariz. 409 (2023). More recently, however, a claimant attempted to stack UIM benefits across multiple insurance policies issued to multiple insured individuals who jointly purchased the policies. State Farm Mutual Automobile v. Balzan, CV-24-0140-PR (Ariz. July 6, 2026).

The plaintiff, Connor Balzan, argued that multiple insured individuals do not constitute “one insured” under the statute, A.R.S. § 20-259.01(H), in his attempt to stack the benefits of multiple policies. Arizona’s Supreme Court rejected that argument and held that joint purchasers of multiple policies from the same insurer constitute “one insured” under the statute.

Mr. Balzan was injured in an automobile accident on April 5, 2019, and sustained injuries leading to medical expenses that exceeded the responsible party’s insurance coverage. Mr. Balzan thereafter sought UIM benefits from his insurer, State Farm. Mr. Balzan argued that he was entitled to the UIM benefits of his own policy as well as the stacked benefits of four policies purchased by his parents because he was part of their household at the time of the underlying collision.

State Farm paid Mr. Balzan the UIM benefits of his own policy and one of his parents’ policies, in line with A.R.S. § 20-259.01(H). Despite this, Mr. Balzan argued that he was entitled to the benefits of the three additional policies because each individual who contributed to paying the policy premium constituted a separate purchaser and, therefore, a separate insured. Interestingly, the trial court, Arizona Court of Appeals, and Supreme Court all rejected this position, albeit for somewhat different reasons. Balzan, ¶¶ 5–7.

Ultimately, the Supreme Court rejected Mr. Balzan’s argument because it would undermine the statute’s language and “leave insurers unable to determine the scope of subsection (H) from the policy itself.” Balzan, ¶ 19. Instead, the Supreme Court held that all named insureds on a policy constitute “one insured” for the purposes of the anti-stacking provisions of § 20-259.01(H). Thus, insurers can continue to limit stacking according to the terms of that subsection, even in cases of multiple individuals who jointly purchase a policy, such as a married couple.

Read the entire opinion here.

[1] The full text of subsection (H) reads: “Uninsured and underinsured motorist coverages are separate and distinct and apply to different accident situations. Underinsured motorist coverage shall not provide coverage for a claim against an uninsured motorist in addition to any applicable uninsured motorist coverage. If multiple policies or coverages purchased by one insured on different vehicles apply to an accident or claim, the insurer may limit the coverage so that only one policy or coverage, selected by the insured, shall be applicable to any one accident. If the policy does not contain a statement that informs the insured of the insured’s right to select one policy or coverage as required by this subsection, within thirty days after the insurer receives notice of an accident, the insurer shall notify the insured in writing of the insured’s right to select one policy or coverage. For the purposes of this subsection, “insurer” includes every insurer within a group of insurers under a common management.”

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Christian, Dichter & Sluga Congratulates Associate Madison Shanley on Admission to the U.S. District Court for the District of Arizona

Paul Manley — Tue, 30 Jun 2026 18:55:54 +0000

Christian, Dichter & Sluga is proud to announce that Associate Attorney Madison Shanley has been officially admitted to practice before the United States District Court for the District of Arizona.

This admission marks another significant milestone in Madison’s legal career and further expands her ability to advocate for clients in both state and federal court. It also reflects the dedication, professionalism, and passion for advocacy that have defined her career from the very beginning.

Madison’s commitment to the legal profession began during high school through mock trial competitions, where she discovered her passion for courtroom advocacy and criminal defense. She continued to develop those skills at Michigan State University, earning a degree in Political Theory and Constitutional Democracy through the James Madison Honors College while distinguishing herself as an accomplished mock trial and moot court competitor. During her undergraduate career, she founded the MSU Undergraduate Moot Court Association and earned numerous individual advocacy awards.

She later attended the Sandra Day O’Connor College of Law at Arizona State University, where she built an impressive record of success in trial advocacy and oral argument competitions. While participating in Arizona’s Rule 39 program, Madison gained valuable courtroom experience by assisting with DUI trials, conducting evidentiary hearings, and representing real clients under the supervision of licensed attorneys. Her dedication to advocacy earned her numerous honors, including the Janet S. Muller Oral Advocacy Award, Order of the Barristers, Best Overall Advocate at the National Trial Advocacy Competition, and multiple first-place finishes in prestigious advocacy competitions.

Today, Madison brings that same passion, preparation, and commitment to every client she represents at Christian, Dichter & Sluga. In addition to serving clients, she continues to give back to the legal community by coaching Sun Devil Mock Trial, mentoring the next generation of trial advocates.

Madison’s admission to the United States District Court for the District of Arizona is a testament to her continued professional growth and unwavering commitment to excellence in the practice of law. We are proud to celebrate this achievement and look forward to her continued success as she serves our clients and our community.

Please join us in congratulating Madison on this well-deserved accomplishment.

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Jeffrey Hutchins, J.P. Harrington Bisceglia, and Amanda Taylor Named as Shareholders of Christian, Dichter & Sluga

CDSAdmin — Tue, 18 Jun 2024 11:38:45 +0000

CDS is pleased to announce that Jeffrey Hutchins, J.P. Harrington Bisceglia, and Amanda Taylor have been made Shareholders of CDS.

In recognition of their leadership, legal talent, and hours of dedicated service to the firm, CDS has conferred shares in the firm to Jeffrey Hutchins, Jeanmarie (J.P.) Harrington Bisceglia, and Amanda Taylor. We’re thrilled to announce them as our newest shareholders and are confident that the future of the firm is in amazing hands.

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Christian, Dichter & Sluga Recognized by Chambers USA

CDSAdmin — Tue, 18 Jun 2024 03:55:21 +0000

CDS ranked as a Band One Firm by Chambers USA with partners Gena Sluga and Amanda Taylor receiving individual recognition.

We are proud to share that our firm again has been recognized by Chambers and Partners–a leading legal industry rankings organization–in its 2024 Chambers USA practice rankings. Christian, Dichter & Sluga has been recognized as a Band One–Insurance firm in Arizona; only five Arizona law firms have been ranked as Band One firms in this practice area. In addition, CDS partners Gena L. Sluga and Amanda Taylor (pictured) were individually recognized for their work in Insurance, which is the firm’s core practice area. Chambers rankings are based upon several qualities, including technical legal ability, professional conduct, client service, commercial vision, business understanding, diligence, commitment, and other qualities most valued by the clients.

This achievement would not have been possible without the trust and support of our firm’s incredible insurance clients. Christian, Dichter & Sluga, Ms. Sluga and Ms. Taylor are honored by this recognition and the kind words shared by clients during the research process.

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2024 CDS Super Lawyers Announced

CDSAdmin — Tue, 30 Apr 2024 07:51:23 +0000

As a boutique insurance coverage and litigation firm, Christian, Dichter & Sluga has worked hard to earn the respect of its peers in the Southwest. With each recognition of a lawyer in our firm, we appreciate the validation of the efforts of our team to provide the best possible resolution to our clients while working cooperatively with our peers. From our founding partners to our Rising Star, with each case we endeavor to live up to the term SuperLawyer.

Congratulations to Doug Christian, Gena Sluga, JP Harrington Bisceglia and Amanda Taylor for recognition in Insurance Coverage; Stephen Dichter in White Collar Criminal Defense; Jeff Hutchins for recognition in Business Litigation and Justin Vanderveer for recognition as a Rising Star in Insurance Coverage.

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