Arizona Revised Statutes

Ariz. Rev. Stat. § 12-548 (2026)

Contract in writing for debt; six year limitation; choice of law

✓ current as of May 2026
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A. An action for debt shall be commenced and prosecuted within six years after the cause of action accrues, and not afterward, if the indebtedness is evidenced by or founded on either of the following:

1. A contract in writing that is executed in this state.

2. A credit card as defined in section 13-2101, paragraph 3, subdivision (a).

B. If there is a conflict between another jurisdiction and this state relating to the statute of limitations for a debt action as described in subsection A of this section, this section applies.

 

Notes of Decisions
Cited in 139 cases (40 in the last 5 years), 1959–2025 · leading case: Gust, Rosenfeld & Henderson v. Prudential Ins. Co. of Am., 898 P.2d 964 (Ariz. 1995).
Gust, Rosenfeld & Henderson v. Prudential Ins. Co. of Am., 898 P.2d 964 (Ariz. 1995). · cites it 10× “DISCUSSION The parties agree that the applicable statute of limitations is A.R.S. § 12-548, which allows a party to sue for breach of a written contract "within six years after the cause of action accrues.”
Zuckerman v. Transamerica Ins., 650 P.2d 441 (Ariz. 1982). · cites it 8× “See A.R.S. § 12-548; Eureka-Security Fire & Marine Insurance *143 Co.”
Woodward v. Chirco Const. Co., Inc., 687 P.2d 1275 (Ariz. Ct. App. 1984). · cites it 10× “The appellant contends that the warranty breach comes within A.R.S. § 12-548, which provides: “An action for debt where indebtedness is evidenced by or founded upon a contract in writing executed within the state shall be commenced and prosecuted within six years after the cause…”
De Anza Land & Leisure Corp. v. Raineri, 669 P.2d 1339 (Ariz. Ct. App. 1983). · cites it 12× “A.R.S. § 12-548 provides as follows: An action for debt where indebtedness is evidenced by or founded upon a contract in writing .”
Cheatham v. Sahuaro Collection Serv., Inc., 577 P.2d 738 (Ariz. Ct. App. 1978). · cites it 8× “The trial court granted Sahuaro’s motion for summary judgment, and Cheatham has appealed, arguing that the obligation is barred by the statute of limitations (A.R.S. § 12-548). We agree with the appellant, and, therefore, reverse.”
Miller Designs v. US Bank, 418 P.3d 1038 (Ariz. Ct. App. 2018). · cites it 4× “” A.R.S. § 12-548(A)(1). “The defense of the statute of limitations is a personal privilege that a debtor or one in privity may elect to urge or waive.”
Ader v. Est. of Felger, 375 P.3d 97 (Ariz. Ct. App. 2016). · cites it 2× “2d at 966 (interpreting A.R.S. § 12-548, which uses “accrue”); Anson v.”
City of Tucson v. Clear Channel Outdoor, Inc., 181 P.3d 219 (Ariz. Ct. App. 2008). · cites it 2× “2d at 966 (interpreting A.R.S. § 12-548); Sato v. Van Denburgh, 123 Ariz.”
Long v. Buckley, 629 P.2d 557 (Ariz. Ct. App. 1981). · cites it 5× “Second, appellants assert that they had a claim against appellees on a written contract which had a six year period of limitations under A.R.S. § 12-548, 2 and that the complaint against Buckley was therefore timely filed as to the contract claim.”
Navy Fed. Credit Union v. Jones, 930 P.2d 1007 (Ariz. Ct. App. 1996). · cites it 6× “In this appeal from summary judgment we must decide when the six-year statute of limitations in A.R.S. § 12-548 begins to run on an unmatured installment obligation that contains an optional acceleration clause.”
Flagstaff Affordable Hous. Ltd. P'ship v. Design All., Inc., 223 P.3d 664 (Ariz. 2010). · cites it 2× “The court of appeals affirmed the dismissal of the negligence claim but reversed the dismissal of the contract claim, holding that the six-year limitations period in AR.S. § 12-548 applied. Id. ¶ 20 The builder petitioned for review, arguing that breach of an implied warranty is…”
La Canada Hills Ltd. P'ship v. Kite, 171 P.3d 195 (Ariz. Ct. App. 2007). · cites it 5× “¶4 Kite moved for summary judgment, contending La Canada’s claims were barred by the applicable statute of limitations for contract actions because it had known of Kite’s alleged failure to make payments at the latest in December 1995, nearly ten years before it sued her. The…”
— Ariz. Rev. Stat. § 12-548(A) — 9 cases
Eans-Snoderly v. Snoderly, 473 P.3d 337 (Ariz. Ct. App. 2020).
Thomas-Hoffman v. Hoffman (Ariz. Ct. App. 2025).
North v. Ubiquity (Ariz. Ct. App. 2020).
Depetris v. Amelio Enter. (Ariz. Ct. App. 2020).
Webster Bank v. Mutka (Ariz. Ct. App. 2021).
— Ariz. Rev. Stat. § 12-548(A)(1) — 26 cases
Miller Designs v. US Bank, 418 P.3d 1038 (Ariz. Ct. App. 2018). “” A.R.S. § 12-548(A)(1). “The defense of the statute of limitations is a personal privilege that a debtor or one in privity may elect to urge or waive.”
Blood Sys., Inc. v. Roesler, 972 F. Supp. 2d 1150 (D. Ariz. 2013).
Broadband v. Satcom, 418 P.3d 1055 (Ariz. Ct. App. 2018).
— Ariz. Rev. Stat. § 12-548(A)(2) — 4 cases
Mertola LLC v. Alberto santos/arlene Santos, 422 P.3d 1028 (Ariz. 2018).
Mertola, LLC v. Santos, 390 P.3d 812 (Ariz. Ct. App. 2017).
U. S. Bank v. Taylor (Ariz. Ct. App. 2022).
— Ariz. Rev. Stat. § 12-548(B) — 1 case
North v. Ubiquity (Ariz. Ct. App. 2020).
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