Ariz. Rev. Stat. » Title 12
Arizona Revised Statutes

Ariz. Rev. Stat. § 12-522 (2026)

Real property claimed only by right of possession; two year limitation

✓ current as of May 2026
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When a party in possession claims real property by right of possession only, actions to recover possession from him shall be commenced within two years after the cause of action accrues and not afterward. In such actions defendant is not required to show title or color of title from and under the sovereignty of the soil as against the plaintiff who shows no better right.

Notes of Decisions
Cited in 8 cases (4 in the last 5 years), 1969–2025 · leading case: Maycock v. Asilomar Dev., Inc., 88 P.3d 565 (Ariz. Ct. App. 2004).
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Maycock v. Asilomar Dev., Inc., 88 P.3d 565 (Ariz. Ct. App. 2004). · cites it 2× “Asilomar contended therefore that the defects were not latent, or if they were latent, they were discovered within the first seven years, and so were barred by A.R.S. § 12-522. ¶ 8 The Maycocks opposed the motion and filed a simultaneous motion for an extension of time to…”
State v. Jackson, 908 P.2d 1081 (Ariz. Ct. App. 1995). · cites it 2× “, A.R.S. §§ 12-522 et seq. (1992 and Supp.1995), 28-1868 (1989), 38-602(A) (1985), 47-2725(A) (1988).”
Lofts at Fillmore Condo. Ass'n v. Reliance Com. Constr., Inc., 189 P.3d 426 (Ariz. Ct. App. 2008). · cites it 2× “These holdings are also consistent with our constitutional structure, described briefly above, placing the primary law-making function in the legislative branch and the adjudicative function in the judicial branch.”
Dominguez v. Dominguez, 567 P.3d 81 (Ariz. 2025). · cites it 2× “See A.R.S. §§ 12-522 through -526. Here, we are concerned with § 12-524, which applies to quiet title actions involving a lot in a city or town.”
City of Tucson v. Melnykovich, 457 P.2d 307 (Ariz. Ct. App. 1969). “§§ 12-522,12-523 and 12-526. 3 . Portions of Forsstrom were overruled in County of Mohave v.”
Cruger v. Blansette (Ariz. Ct. App. 2022). · cites it 3× “3 Relying on A.R.S. §§ 12-522 and -526, Blansette contends that Cruger’s forcible detainer claim is time-barred, but neither statute applies to this case.”
Nguyen v. Nguyen (Ariz. Ct. App. 2024). · cites it 2× “See A.R.S. § 12-522. The superior court found the defense waived because Quy and Ahn never raised the defense by motion and instead litigated the case for two years.”
Golden Star Mine LLC v. Renegade Mining & Milling LLC (D. Ariz. 2025). “16 § 12-522. Mining claims are included in the meaning of real property under the statute.”
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