Arizona Revised Statutes

Ariz. Rev. Stat. § 12-543 (2026)

Oral debt; stated or open account; relief on ground of fraud or mistake; three year limitation

✓ current as of May 2026

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There shall be commenced and prosecuted within three years after the cause of action accrues, and not afterward, the following actions:

1. For debt where the indebtedness is not evidenced by a contract in writing.

2. Upon stated or open accounts other than such mutual and current accounts as concern the trade of merchandise between merchant and merchant, their factors or agents, but no item of a stated or open account shall be barred so long as any item thereof has been incurred within three years immediately prior to the bringing of an action thereon.

3. For relief on the ground of fraud or mistake, which cause of action shall not be deemed to have accrued until the discovery by the aggrieved party of the facts constituting the fraud or mistake.

Notes of Decisions

Cited in 163 cases (31 in the last 5 years), 1957–2026 · leading case: Skydive Arizona, Inc. v. Hogue, 360 P.3d 153 (Ariz. Ct. App. 2015).

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Skydive Arizona, Inc. v. Hogue, 360 P.3d 153 (Ariz. Ct. App. 2015). · cites it 10× “Skydive Arizona responded that the appropriate limitations period was three years because the United *363 States Court of Appeals for the Ninth Circuit had already ruled that the analogous state law was A.R.S. § 12-543, Arizona’s fraud statute.”

Gust, Rosenfeld & Henderson v. Prudential Ins. Co. of Am., 898 P.2d 964 (Ariz. 1995). · cites it 8× “" A.R.S. § 12-543(3). *592 This is that sort of case.”

Coulter v. Grant Thornton, LLP, 388 P.3d 834 (Ariz. Ct. App. 2017). · cites it 4× “See A.R.S. § 12-543(3); Coronado Dev. Corp. v.”

Hall v. Romero, 685 P.2d 757 (Ariz. Ct. App. 1984). · cites it 4× “” However, plaintiffs urge us to apply either the three-year statute, A.R.S. § 12-543, which applies to actions grounded in fraud; or the four-year general statute, A.”

Woodward v. Chirco Const. Co., Inc., 687 P.2d 1275 (Ariz. Ct. App. 1984). · cites it 6× “” The author states under the heading “Contract statutes versus tort statutes” (in Arizona, A.R.S. § 12-543 or A.R.S. § 12 — 548 versus A.”

Backman v. Backman, 621 P.2d 920 (Ariz. Ct. App. 1980). · cites it 16× “The main issue raised by appellants is whether the trial court erred in holding that the statute of limitations, A.R.S. § 12-543(3), did not bar appellee’s action to set aside the appellants’ conveyance of real property as a fraudulent conveyance, pursuant to A.”

Crook v. Anderson, 565 P.2d 908 (Ariz. Ct. App. 1977). · cites it 4× “§ 12-542) or the three-year statute for fraud (A.R.S. § 12-543) applied, which in either case barred the action.”

Transamerica Ins. v. Trout, 701 P.2d 851 (Ariz. Ct. App. 1985). · cites it 4× “He contends that the three year period provided by A.R.S. § 12-543 began to run on September 17, 1974, the date the quitclaim deed from St.”

Ranch Realty, Inc. v. Dc Ranch Realty, LLC, 614 F. Supp. 2d 983 (D. Ariz. 2007). · cites it 4× “§ 12-542(3)), or three years as fraud (A.R.S. § 12-543(3)). The issue of which limitations period applies to trademark infringement appears to be one of first impression.”

Moore v. Browning, 50 P.3d 852 (Ariz. Ct. App. 2002). · cites it 2× “They simply assert they alleged a common law cause of action in an effort to have the three-year statute of limitations apply in *108 stead of the statute of repose in § 44-1009.”

M & I BANK, FSB v. Coughlin, 805 F. Supp. 2d 858 (D. Ariz. 2011). · cites it 4× “, A.R.S. § 12-543(3) (three-year limitations period for fraud, which begins to run upon “discovery by the aggrieved party of the facts constituting the fraud or mistake”); A.”

Sato v. Van Denburgh, 599 P.2d 181 (Ariz. 1979). · cites it 2× “WHICH STATUTE APPLIES? We must first determine which statute of limitations applies to the íacts in the instant case. There are, we believe, three statutes which might apply: A.”

Show all 163 citing cases →

— Ariz. Rev. Stat. § 12-543(1) — 20 cases

Redhair v. Kinerk, Beal, Schmidt, Dyer & Sethi, P.C., 183 P.3d 544 (Ariz. Ct. App. 2008).

Amfac Distrib. Corp. v. Miller, 673 P.2d 795 (Ariz. Ct. App. 1983).

Woodward v. Chirco Const. Co., Inc., 687 P.2d 1275 (Ariz. Ct. App. 1984). “” The author states under the heading “Contract statutes versus tort statutes” (in Arizona, A.R.S. § 12-543 or A.R.S. § 12 — 548 versus A.”

Anonymous Wife v. Anonymous Husband, 739 P.2d 794 (Ariz. 1987).

Cavan v. Maron, 182 F. Supp. 3d 954 (D. Ariz. 2016).

— Ariz. Rev. Stat. § 12-543(2) — 6 cases

Builders Supply Corp. v. Marshall, 352 P.2d 982 (Ariz. 1960).

Flori Corp. v. Fitzgerald, 810 P.2d 599 (Ariz. Ct. App. 1990).

Krumtum v. Burton, 532 P.2d 510 (Ariz. 1975).

Broadband v. Satcom, 418 P.3d 1055 (Ariz. Ct. App. 2018).

Mertola, LLC v. Santos, 390 P.3d 812 (Ariz. Ct. App. 2017).

— Ariz. Rev. Stat. § 12-543(3) — 48 cases

Gust, Rosenfeld & Henderson v. Prudential Ins. Co. of Am., 898 P.2d 964 (Ariz. 1995). “" A.R.S. § 12-543(3). *592 This is that sort of case.”

Skydive Arizona, Inc. v. Hogue, 360 P.3d 153 (Ariz. Ct. App. 2015). “Skydive Arizona responded that the appropriate limitations period was three years because the United *363 States Court of Appeals for the Ninth Circuit had already ruled that the analogous state law was A.R.S. § 12-543, Arizona’s fraud statute.”

Coulter v. Grant Thornton, LLP, 388 P.3d 834 (Ariz. Ct. App. 2017). “See A.R.S. § 12-543(3); Coronado Dev. Corp. v.”

Backman v. Backman, 621 P.2d 920 (Ariz. Ct. App. 1980). “The main issue raised by appellants is whether the trial court erred in holding that the statute of limitations, A.R.S. § 12-543(3), did not bar appellee’s action to set aside the appellants’ conveyance of real property as a fraudulent conveyance, pursuant to A.”

Ranch Realty, Inc. v. Dc Ranch Realty, LLC, 614 F. Supp. 2d 983 (D. Ariz. 2007). “§ 12-542(3)), or three years as fraud (A.R.S. § 12-543(3)). The issue of which limitations period applies to trademark infringement appears to be one of first impression.”

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