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Arizona List Transparency Petition
PETITION TO THE ARIZONA SUPREME COURT
Protect Consumers and Ensure Fair Representation in Arizona's Defensive Driving School Directory
To: Arizona Supreme Court — Administrative Office of the Courts (AOC)
Dear Arizona Supreme Court Administration,
The Court's defensive driving school directory should educate and protect consumers—not provide disproportionate marketing exposure to operators controlling multiple school names.
This principle was expressly recognized in former ACJA § 7-205(D)(4)(i), which stated that the directory was not intended to serve as a marketing tool for owners offering the same options through different certified schools. The revised rule, effective November 15, 2026, continues to recognize the directory's public-education purpose under ACJA § 7-205.15(B)(1)(b).
The Problem
Our August 15, 2026 review identified 218 online school listings, with 201 (92.2%) sharing contact or operational information across 19 apparent multi-school groups.
The five largest apparent groups identified were:
Morena / Keller–Mozafari: 34 schools associated with Marla Keller and Borna Mozafari contacts.
American Roadways / Kevin Frei: 26 linked schools, with 25 conservatively attributed after accounting for an approved sale.
EZ AZ / Hallums: 25 schools associated with Hallums-family and Bea Mena contacts.
Riedel Online Video: 23 schools associated with Bill and Michelle Riedel contacts.
NiSE / James Alex Smith: 20 schools associated with James Alex Smith.
These findings reflect documented contact or operational connections. They do not, by themselves, establish common legal ownership or control. That determination should be made by the AOC using its certification and ownership records.
The Question the Court Should Ask
Why does one apparent operating network have 34 separate school listings?
Are these genuinely independent businesses, or are motorists being directed through different school names into substantially the same management, customer service, payment systems, and certificate-processing operations?
If affiliated schools receive separate randomized positions, the result may disproportionately favor larger operating groups over independent schools.
Consumers Are Also Affected
A motorist who has a bad experience with one school may select another, unaware that both could be operated by the same organization.
Consumers deserve to know who they are doing business with, particularly when choosing from an official court-maintained directory.
Our Recommended Solution: One Owner, One Listing
We respectfully request that the Arizona Supreme Court direct the AOC to:
Verify common ownership and operational control among certified defensive driving schools using official records and other reliable evidence.
Provide one randomized listing per verified ownership or control group, rather than a separate first-level position for every school name within that group.
Include a "View Schools" drop-down displaying every certified school within the group, allowing consumers to select their preferred school or course.
Preserve individual listings for independent schools while ensuring every certified school remains available to consumers.
Preserve the directory's consumer-protection purpose, including the principle that separate school names should not create disproportionate state-generated marketing exposure for a common owner.
This approach preserves every school's certification and the consumer's ability to choose while promoting transparency and fair competition.
Our Request
We respectfully request the Court's formal review of this issue and consideration of appropriate administrative or rule changes to:
Protect consumers. Ensure fair competition. Preserve the public-service purpose of Arizona's defensive driving school directory.
The governing question remains:
Should an operator controlling multiple certified school names receive more opportunities for visibility in a court-operated randomized directory than an independently owned school?
We believe every independently controlled school or verified ownership group deserves fair representation.
Respectfully,
The Undersigned Supporters of Fair and Transparent Defensive Driving School Listings
Electronic Signature and Consent
By signing this petition, I confirm that I have reviewed its contents, support the requested AOC review and proposed directory reforms, and authorize my name, organization (if provided), and electronic signature to be included in the petition submitted to the Arizona Supreme Court and its Administrative Office of the Courts.
Supporting signatures will be collected electronically and attached to the final submitted petition.