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

✓ text as last checked Oct. 2026 (this copy records no edition or section history)
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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× “Section 12-524 provides as follows: An action to recover a lot located in a city or town from a person having a recorded deed therefor, who claims ownership and has paid the taxes thereon, shall be brought within five years after the cause of action accrues, and not afterward,…”
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, No. 1 CA-CV 21-0649 (Ariz. Ct. App. Sept. 8, 2022). · cites it 3× “§ 12-526 precludes a landowner from bringing an action to recover property that has been adversely possessed by another for more than ten years.”
Nguyen v. Nguyen, No. 1 CA-CV 23-0360 (Ariz. Ct. App. Mar. 12, 2024). · cites it 2× “§ 12-1104 does not require filing a motion to dismiss on statute-of-limitations grounds. But A.R.S. § 12-1104 is a jurisdictional statute, and it applies only when the "plaintiff would have a defense by reason of limitation.”
Golden Star Mine LLC v. Renegade Mining & Milling LLC, No. 2:24-cv-02386 (D. Ariz. May 15, 2025). “16 § 12-522. Mining claims are included in the meaning of real property under the statute.”
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