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(602) 345-1818Most people assume the left-turning driver is automatically at fault. That’s what the insurance adjuster on the other side wants you to assume, too. It’s a useful shortcut for closing the file cheap. In our experience handling left-turn crashes across Maricopa County, that shortcut is wrong more often than clients expect.
A left turn accident claim in Arizona starts with a statutory yield rule, but it doesn’t end there. Signal phase, oncoming speed, and sight lines can all rebut the presumption against the turning driver. This article walks through the actual law, the three evidence categories that decide these cases, how comparative fault works when both drivers share blame, and what to do in the first 72 hours to protect the claim. If you want case-specific help, our Phoenix car accident practice handles left-turn crashes across the Valley.
Who wrote this. Jared J. Pehrson is the lead attorney at Impact Legal Car Accident Attorneys in Phoenix. He handles auto crash claims personally, from intake through resolution, and has worked left-turn intersection cases involving protected-arrow disputes, permissive-green yield fights, and EDR-driven speed reconstructions on both the plaintiff and, earlier in his career, the defense side. Everything below reflects how these files actually get built and argued in Arizona, not a generic overview.
Arizona’s left-turn yield rule lives in A.R.S. § 28-772. The statute says that a driver intending to turn left within an intersection, or into an alley, private road, or driveway, must yield to any vehicle approaching from the opposite direction that is close enough to be an immediate hazard.
Two words in that statute do most of the work: “immediate hazard.” A car three blocks away is not an immediate hazard. A car in the next intersection running 55 in a 35 might be. That’s where these cases get interesting, and where a lot of the fighting happens.
Turning-movement crashes are a recurring category in the state’s intersection data. The Arizona Department of Transportation publishes annual Arizona Motor Vehicle Crash Facts, and left-turn and other turning-movement collisions consistently show up as one of the more common manner-of-collision categories at signalized and driveway-access intersections.
Under § 28-772, the turning driver has to make the judgment call. Is the oncoming car close enough, fast enough, or moving in a way that makes the turn unsafe? If yes, wait. If they turn anyway and there’s a crash, they’re presumed to have breached the yield duty.
This is why insurance adjusters lean on § 28-772 so hard. It gives them a clean, one-sentence liability argument: the turning driver turned, the through driver didn’t have to yield, done. That framing works well for them when the facts are simple. It falls apart when the facts aren’t.
The through driver doesn’t get a free pass just because § 28-772 puts the yield duty on the turner. Every driver in Arizona still owes a duty of reasonable care. Two statutes matter most here:
If the oncoming driver was speeding, ran a red, was distracted, or was driving without headlights at night, the yield analysis changes. The turning driver was entitled to assume the oncoming car was obeying the law. If it wasn’t, the “immediate hazard” the turner had to yield to may not have looked like an immediate hazard at all until it was too late.
The fault presumption against the turning driver is rebuttable. That’s the piece most competitor pages skip, and it’s the piece that decides real cases.
Not every left turn is governed by the same signal. There are three basic phases at signalized intersections in Arizona, and each one changes the liability analysis:
Protected left (green arrow). The turning driver has the exclusive right of way. Oncoming traffic has a red. If an oncoming driver enters against that red and hits a left-turning car, the liability picture flips almost entirely: the turner had the arrow, the oncoming driver ran the red. § 28-772 doesn’t do much work here because the turner wasn’t required to yield.
Permissive left (green ball, no arrow). The turner may proceed but must yield to oncoming traffic. This is the classic § 28-772 scenario. The turning driver carries the yield burden.
Yellow arrow or flashing yellow arrow. Turner may proceed with caution and must yield. Same yield burden as a green ball, plus a warning that the phase is ending.
Establishing which phase was active at the moment of impact is often the single most important fact in the case. On a recent file involving a Camelback Road intersection with a flashing yellow arrow, the responding officer wrote the phase as “green” in the narrative. The signal timing log we pulled from the city showed the flashing yellow had been active for 11 seconds when impact occurred. That single documentary correction moved the fault allocation meaningfully in our client’s direction. Signal phase is not a detail. It’s the case.
In practice, left-turn crashes are decided by three buckets of evidence: visibility, speed, and signal phase. Each one comes from different sources. The investigative framework we apply mirrors the multi-source approach the National Highway Traffic Safety Administration uses in its Special Crash Investigations program, which pulls together scene inspection, vehicle inspection, interviews, official reports, medical records, and event data recorder downloads.
Sight-line issues can rebut the fault presumption against the turning driver. Did the sun blind them at 7:15 a.m. on an eastbound approach? Was a parked delivery truck screening cross-traffic? Was foliage overgrowing a median? Was another vehicle in the adjacent left-turn lane blocking the view of oncoming traffic?
We document visibility with scene photographs taken at the same time of day and season, sun-angle calculations, ALPR (automated license plate reader) and municipal traffic camera pulls if available, Google Street View archives, and, in bigger cases, an accident reconstructionist walking the sight lines. A classic example we’ve seen more than once: an oncoming SUV in the through lane hides a motorcycle in the far lane traveling above the limit. The turner never sees the motorcycle. The screening vehicle doesn’t get named in the police report. Without a scene walk within days of the crash, that fact never enters the file.
If the oncoming driver was speeding, the “immediate hazard” analysis changes. Speed is proven through:
Pulling an EDR requires prompt action. Vehicles get repaired, totaled, and sent to salvage yards fast. Once the vehicle is gone, the data usually goes with it. On the files where we’ve successfully rebutted a turner-fault presumption with EDR data, the preservation letter went out within the first week. On the files where we couldn’t, it’s almost always because the vehicle disappeared before we were retained.
Which light was green for whom? Sources include:
The combination of signal-phase evidence plus speed evidence is usually what wins or loses these cases.
Under A.R.S. § 28-667, investigating law enforcement must file a written accident report for crashes they investigate that involve injury, death, or apparent property damage. That report, along with the officer’s diagram and any narrative, is a core piece of evidence in every left-turn claim.
A few things to know about the report:
If you don’t have the report yet, here’s how to get a copy of the Arizona crash report. Get it early. It drives everything that follows.
Arizona uses pure comparative negligence under A.R.S. § 12-2505. Your recovery is reduced by your percentage of fault, but there is no cutoff. Even a driver found 80% at fault still recovers 20% of proven damages. This is a critical difference from states with 50% or 51% bar rules.
Worked example. Say a left-turning driver in Phoenix is hit by an oncoming pickup that was traveling 20 over the limit. Damages total $200,000. A jury assigns 40% fault to the turner (didn’t wait long enough) and 60% to the pickup (excessive speed). The turner recovers $120,000: $200,000 reduced by 40%.
Change the numbers. Say the jury sees it as 60% turner, 40% pickup. Same damages. The turner still recovers $80,000. That’s the piece competitors don’t explain, and it’s the piece that matters most to a client who’s been told by the other side’s adjuster that they’re “at fault, so there’s nothing to recover.” That’s not how Arizona law works. For a deeper walk-through, read more on Arizona’s comparative negligence rule.
Insurers in left-turn cases use comparative fault two ways:
The answer to both is the same: build the evidentiary record early enough that the adjuster’s opening theory has to be abandoned before mediation, not after.
Left-turn crashes at intersection speeds tend to produce lateral-impact injury patterns similar to T-bone (broadside) collisions, plus frontal-impact injuries when the turner is struck head-on partway through the turn. Common injuries include:
Damages are documented through emergency room records, imaging (X-ray, CT, MRI), treating physician notes, physical therapy records, wage-loss documentation from the employer, and, in serious cases, a life-care plan and a vocational expert’s report. Claim value depends on injury severity, treatment history, liability proof, available insurance, and how well damages are documented. We don’t publish “typical” settlement ranges for left-turn cases because every case turns on those variables.
Two deadlines matter in every Arizona left-turn claim.
The two-year statute of limitations. Under A.R.S. § 12-542, you have two years from the date of the crash to file a personal injury lawsuit. Miss it and the claim is barred, period. Details on how the clock runs are in our page on Arizona’s filing deadline for car accident claims.
The 180-day government notice. If the other driver was a City of Phoenix employee, a state employee, a county employee, or driving a government vehicle, A.R.S. § 12-821.01 requires a formal notice of claim served within 180 days of the crash. Miss the notice and the claim against the government is barred even if the two-year SOL hasn’t run. This trips people up in crashes involving city vehicles, transit buses, and on-duty officers.
If the oncoming driver was uninsured or underinsured, your own uninsured/underinsured motorist coverage becomes the recovery source. UM/UIM claims have their own contractual deadlines and notice requirements written into your policy, and those deadlines can be shorter than the two-year SOL. Read the declarations page, not the summary.
The first three days do more to shape the claim than the next three months. Concrete steps:
No. A.R.S. § 28-772 creates a yield duty for the turning driver, and that duty produces a presumption of fault when the turner gets hit. But the presumption is rebuttable. Excessive speed, a red-light entry, or blocked sight lines on the part of the oncoming driver can shift fault, sometimes majority fault, back to the through driver.
You can still recover. Arizona uses pure comparative negligence under A.R.S. § 12-2505, which reduces your recovery by your percentage of fault but never bars it. A left-turning driver found 60% at fault on $100,000 in damages still recovers $40,000.
Speed is proven through event data recorder (“black box”) downloads from the vehicle, dashcam footage, skid mark measurements, crush-damage analysis, and signal-timing calculations. EDR data has to be preserved before the vehicle is repaired or sent to salvage, so acting quickly matters.
A protected left turn (green arrow) means oncoming traffic has a red light. If you were hit while turning under a green arrow, the analysis flips: the oncoming driver ran a red, and § 28-772 doesn’t create a yield duty on you. Signal-timing logs from the municipality can confirm the phase at the moment of impact.
Two years from the crash date to file a lawsuit, under A.R.S. § 12-542. If the other driver was a government employee or driving a government vehicle, you also have to serve a formal notice of claim within 180 days under A.R.S. § 12-821.01.
Rarely. The first offer in a left-turn case usually assumes 100% fault against the turning driver and ignores evidence that could shift the analysis. It also frequently omits future medical costs, wage loss, and non-economic damages. Get the claim evaluated before you sign anything.
If you were the turning driver, the other side is probably telling you the claim is worthless. If you were the oncoming driver, they may be telling you it’s open and shut. Neither is usually true.
We handle left-turn cases across Maricopa County. Free case review, no attorney’s fees unless we recover (case costs and fee terms are set out in the written agreement).
Talk to us before talking to insurance: (602) 345-1818
By Jared J. Pehrson | Impact Legal Car Accident Attorneys