Arizona Revised Statutes
Ariz. Rev. Stat. § 12-821 (2026)
General limitation; public employee
✓ current as of May 2026
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All actions against any public entity or public employee shall be brought within one year after the cause of action accrues and not afterward.
Notes of Decisions
Cited in 222
cases (53 in the last 5 years), 1958–2026 · leading case: Deer Valley Unified Sch. Dist. No. 97 v. Houser, 152 P.3d 490 (Ariz. 2007).
Deer Valley Unified Sch. Dist. No. 97 v. Houser, 152 P.3d 490 (Ariz. 2007). “2d 271, 274 (1975) (quoting A.R.S. § 12-821 (1956)). Because A.R.S. § 12-821 did not, “by its terms, define what constitutes a claim,” it was “necessary for [the court of appeals] to determine what constitutes a claim within the meaning of A.”
Pritchard v. State, 788 P.2d 1178 (Ariz. 1990). “The trial court granted the motion to dismiss and a divided court of appeals affirmed on the ground that plaintiff had failed to file a claim against the state within the twelvemonth period prescribed by A.R.S. § 12-821. We granted review pursuant to Rule 23, Ariz.”
Grimm v. Arizona Bd. of Pardons & Paroles, 564 P.2d 1227 (Ariz. 1977). “Does appellants' failure to fulfill the requirements of A.R.S. § 12-821 preclude this suit? 2. Do the Arizona Board of Pardons and Paroles and its individual members enjoy absolute immunity from civil suit for its decision to grant parole? 3.”
Dube v. Likins, 167 P.3d 93 (Ariz. Ct. App. 2007). “¶ 7 Under A.R.S. § 12-821, “[a]U actions against any public entity or public employee shall be brought within one year after the cause of action accrues and not afterward.”
Hollingsworth v. City of Phoenix, 793 P.2d 1129 (Ariz. Ct. App. 1990). “We once again consider an appeal of a dismissal of an action against a public entity because the plaintiff allegedly did not comply with A.R.S. § 12-821. The trial court concluded that the appellant Grant Hollingsworth (Hollingsworth) failed to submit a "claim" to the City of…”
Johnson v. Superior Court, Pima Cnty., 763 P.2d 1382 (Ariz. Ct. App. 1988). “Former A.R.S. § 12-821 provided: Persons having claims on contract or for negligence against the state, which have been disallowed, may on the terms and conditions set forth in this article, bring action thereon against the state, and prosecute the action to final judgment.”
Rogers v. Bd. of Regents of the Univ. of Arizona, 311 P.3d 1075 (Ariz. Ct. App. 2013). “The trial court found that Schugg’s actions against ABOR alleging an easement in the road that traversed ABOR’s property were time-barred under AR.S. § 12-821. Schugg contends the court erred by dismissing his claims with prejudice and by granting summary judgment in favor of…”
Mccloud v. State, Dept. of Pub. Saf., 170 P.3d 691 (Ariz. Ct. App. 2007). “See A.R.S. § 12-821. In response, McCloud argued the late filing of the complaint had been the result of “excusable neglect” and therefore the “statute of limitations should be equitably tolled.”
State v. Mabery Ranch, Co., L.L.C., 165 P.3d 211 (Ariz. Ct. App. 2007). “The State argued that the one-year limitations period established in A.R.S. § 12-821 (2003) had run on each count, and further argued that Mabery had failed to file a notice of claim pursuant to A.”
Cook v. Town of Pinetop-Lakeside, 303 P.3d 67 (Ariz. Ct. App. 2013). “The Town subsequently filed a motion for summary judgment arguing that Cook’s claim was barred by the one-year statute of limitations under A.R.S. § 12-821. Cook responded by arguing that § 12-821 did not apply and that factual issues precluded summary judgment.”
Flood Control Dist. v. Gaines, 43 P.3d 196 (Ariz. Ct. App. 2002). “NOTES [1] In two similar cases, Maricopa County Superior Court judges have ruled that A.R.S. §§ 12-821 and/or -821.01(A) (1994) (barring causes of action against public entity if notice of claim not filed within 180 days) supercede earlier cases.”
Dassinger v. Oden, 606 P.2d 41 (Ariz. Ct. App. 1979). “The controversy below and on appeal is whether appellants complied with the claim requirements of A.R.S. § 12-821. Fulfilling these requirements is a jurisdictional prerequisite to the institution of a negligence action against the State.”
— Ariz. Rev. Stat. § 12-821(A) — 22 cases
Johnson v. Superior Court, Pima Cnty., 763 P.2d 1382 (Ariz. Ct. App. 1988). “Former A.R.S. § 12-821 provided: Persons having claims on contract or for negligence against the state, which have been disallowed, may on the terms and conditions set forth in this article, bring action thereon against the state, and prosecute the action to final judgment.”
City of Tucson v. Fleischman, 731 P.2d 634 (Ariz. Ct. App. 1986).
Morgan v. City of Phoenix, 785 P.2d 101 (Ariz. Ct. App. 1989).
Arizona Dep't of Revenue v. Dougherty, 29 P.3d 862 (Ariz. 2001).
Pritchard v. State, 788 P.2d 1178 (Ariz. 1990). “The trial court granted the motion to dismiss and a divided court of appeals affirmed on the ground that plaintiff had failed to file a claim against the state within the twelvemonth period prescribed by A.R.S. § 12-821. We granted review pursuant to Rule 23, Ariz.”
— Ariz. Rev. Stat. § 12-821(B) — 2 cases
Pritchard v. State, 788 P.2d 1178 (Ariz. 1990). “The trial court granted the motion to dismiss and a divided court of appeals affirmed on the ground that plaintiff had failed to file a claim against the state within the twelvemonth period prescribed by A.R.S. § 12-821. We granted review pursuant to Rule 23, Ariz.”
Pritchard v. State, 778 P.2d 1346 (Ariz. Ct. App. 1989).
— Ariz. Rev. Stat. § 12-821(C) — 2 cases
Nikolous v. Superior Court, 756 P.2d 925 (Ariz. 1988).
Stokka v. Scottsdale Unified Sch. Dist. (D. Ariz. 2025).
— Ariz. Rev. Stat. § 12-821(E) — 2 cases
Hauskins v. McGillicuddy, 852 P.2d 1226 (Ariz. Ct. App. 1992).
Pritchard v. State, 778 P.2d 1346 (Ariz. Ct. App. 1989).
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