Arizona Revised Statutes

Ariz. Rev. Stat. § 14-3104 (2026)

Claims against decedent; necessity of administration

✓ current as of May 2026
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No proceeding to enforce a claim against the estate of a decedent or his successors may be revived or commenced before the appointment of a personal representative. After the appointment and until distribution, all proceedings and actions to enforce a claim against the estate are governed by the procedure prescribed by this chapter. After distribution a creditor whose claim has not been barred may recover from the distributees as provided in section 14-3934 or from a former personal representative individually liable as provided in section 14-3935. This section has no application to a proceeding by a secured creditor of the decedent to enforce his right to his security except as to any deficiency judgment which might be sought therein.

Notes of Decisions
Cited in 4 cases, 1989–2016 · leading case: Ader v. Est. of Felger, 375 P.3d 97 (Ariz. Ct. App. 2016).
Ader v. Est. of Felger, 375 P.3d 97 (Ariz. Ct. App. 2016). · cites it 3× “Rather, the issue is: How does a court calculate the time limits in § 14-3803(A) when no personal representative has been appointed and, consequently, no notice has been given to creditors? See AR.S. § 14-3104 (“No proceeding to enforce a claim against the estate of a decedent…”
Arizona Health Care Cost Containment Sys. v. Allen, 173 P.3d 448 (Ariz. Ct. App. 2007). · cites it 6× “” A.R.S. § 14-3104 (2005). The statute concludes by expressly stating, “[t]his section has no application to a proceeding by a secured creditor of the decedent to enforce his right to his security except as to any deficiency judgment which might be sought therein.”
Pargman v. Vickers, 96 P.3d 571 (Ariz. Ct. App. 2004). · cites it 2× “§ 14-3104 (2003) bars enforcement of such a claim against a decedent’s estate until a personal representative is appointed to act on behalf of the estate (”[n]o proceeding to enforce a claim against the estate ... may be revived or commenced before appointment of a personal…”
Nuppenau v. Meyer, 774 P.2d 839 (Ariz. Ct. App. 1989). · cites it 2× “A.R.S. § 14-3104 provides in part: No proceeding to enforce a claim against the estate .”
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