To the Honorable Justices of the Arizona Supreme Court:
Please accept this formal petition to amend Rule 31 of the Rules of the Supreme Court of Arizona. The attached documents propose the creation of two specialized, non-lawyer professional categories: the Qualified Administrative Representative (QAR) and the Qualified Regulatory Prosecutor (QRP).
This petition is submitted to expand meaningful access to justice and to establish a robust framework for administrative advocacy and regulatory enforcement. Our proposal includes:
• Competency and Ethical Standards: Establishing rigorous benchmarks for regulatory immersion, specialized training, and adherence to prosecutorial ethics, including Brady disclosure obligations.
• Private Attorney General Framework: Defining the role of the QRP to ensure systemic accountability in administrative and public interest matters.
• Compliance Oversight Structure: Implementing a mandatory supervision model requiring a "Compliance Licensed Attorney" (CLA) for single-state practice and two additional qualified legal professionals (including the option for an LLLP) for multi-jurisdictional practice.
• Statement of Purpose & Impact Statement: Detailing the necessity of these amendments for the public interest and the anticipated positive impacts on administrative efficiency and access to justice.
I request that this petition be posted to the Court Rules Forum for public comment in accordance with Rule 28 of the Rules of the Supreme Court of Arizona.
Respectfully submitted,
Crystal Rebecca Freyer
Agency Director & Executive Director of Developmental Homes
Mecartea & Associates PLLC
Crystal Rebecca Freyer
Agency Director | Founder
Mecartea & Associates PLLC
Limited Licensed Legal Practitioner Under Attorney Oversight
Phone: (480) 761-8138
Email:
[email protected] Web: mecarteaandassociatespllc.durablesites.com
Filed: June 1, 2026
Would amend Rule 31 of the Rules of the Supreme Court of Arizona to create non-lawyer Qualified Administrative Representatives to represent people in administrative hearings and non-lawyer Qualified Regulatory Prosecutors to initiate enforcement actions in adjudicative hearings.
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