On July 14, 2017, a three-judge panel of the U.S. Court of Appeals for the Ninth Circuit ruled, in Lazar v. Kroncke (Case No. 15-15078), that:

• federal law does not preempt Arizona’s revocation-on-divorce (ROD) statute;
• Arizona’s ROD statute is superior to choice-of-law provisions that state otherwise; and
• Arizona’s ROD statute’s effect does not violate the Contracts Clause of the United States Constitution.

The case was successfully argued by Frazer Ryan attorney T.J. Ryan, who prevailed in Arizona district court and again before the Ninth Circuit.