Arizona Revised Statutes

Ariz. Rev. Stat. § 14-3803 (2026)

Limitations on presentation of claims

✓ current as of May 2026

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A. All claims against a decedent's estate that arose before the death of the decedent, including claims of the state and any of its political subdivisions, whether due or to become due, absolute or contingent, liquidated or unliquidated, founded on contract, tort or other legal basis, if not barred earlier by any other statute of limitations or nonclaim statute, are barred against the estate, the personal representative and the heirs and devisees of the decedent, unless presented within the earlier of either:

1. Two years after the decedent's death plus the time remaining in the period commenced by an actual or published notice pursuant to section 14-3801, subsection A or B.

2. The time prescribed by section 14-3801, subsection B for creditors who are given actual notice and within the time prescribed in section 14-3801, subsection A for all creditors barred by publication.

B. A claim that is described in subsection A of this section and that is barred by the nonclaim statute of the decedent's domicile before the giving of notice to creditors in this state is barred in this state.

C. All claims against a decedent's estate that arise at or after the death of the decedent, including claims of the state and any political subdivision, whether due or to become due, absolute or contingent, liquidated or unliquidated, founded on contract, tort or other legal basis, are barred against the estate, the personal representative and the heirs and devisees of the decedent, unless presented as either of the following:

1. A claim based on a contract with the personal representative, within four months after performance by the personal representative is due.

2. Any other claim, within the later of four months after it arises or the time specified in subsection A, paragraph 1 of this section.

D. This section does not affect or prevent any of the following:

1. Any proceeding to enforce any mortgage, pledge or other lien upon property of the estate.

2. To the limits of the insurance protection only, any proceeding to establish liability of the decedent or the personal representative for which he is protected by liability insurance.

3. Collection of compensation for services rendered and reimbursement for expenses advanced by the personal representative or by the attorney or accountant for the personal representative or the estate.

Notes of Decisions

Cited in 30 cases (6 in the last 5 years), 1974–2026 · leading case: Ader v. Est. of Felger, 375 P.3d 97 (Ariz. Ct. App. 2016).

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Ader v. Est. of Felger, 375 P.3d 97 (Ariz. Ct. App. 2016). · cites it 37× “The primary issue presented in this appeal requires us to interpret A.R.S. § 14-3803 and A.R.S. § 14-3108 to determine whether Ader’s claims against the Estate are time-barred because no probate proceeding was initiated in Arizona within two years following Dan Felger’s death.”

In Re Est. of Van Der Zee, 265 P.3d 439 (Ariz. Ct. App. 2011). · cites it 20× “§ 14-3803(A)(2). For purposes of our review, we assume without deciding that Siebe is a known creditor who should have been served written notice, so he had at least two years pursuant to AR.”

Evitt-Thorne v. Hiatt (In re Evitt), 429 P.3d 1146 (Ariz. Ct. App. 2018). · cites it 30× “Accordingly, and for reasons that follow, we affirm the superior court's ruling barring Judith Evitt-Thorne's claim against her ex-husband's estate as time-barred under A.R.S. § 14-3803. FACTS AND PROCEDURAL BACKGROUND ¶ 2 Evitt-Thorne and Charles Evitt divorced in 1987.”

Arizona Health Care Cost Containment Sys. v. Allen, 173 P.3d 448 (Ariz. Ct. App. 2007). · cites it 8× “A.R.S. § 14-3803; see also Harter v. Lenmark, 443 N.”

Realty Assocs. v. Valley Nat'l Bank, 738 P.2d 1121 (Ariz. Ct. App. 1986). · cites it 7× “The applicable Arizona statute is A.R.S. § 14-3803(A) which provides: A. All claims against a decedent’s estate which arose before the death of the decedent, including claims of the state and any subdivision thereof, whether due or to become due, absolute or contingent,…”

Pargman v. Vickers, 96 P.3d 571 (Ariz. Ct. App. 2004). · cites it 4× “Section 14-3803(D) states: "This section does not affect or prevent any of the following: .”

Est. of Page v. Litzenburg, 865 P.2d 128 (Ariz. Ct. App. 1993). · cites it 3× “The issue is whether Litzenburg’s oral contract claim, upon which she recovered, materially varied from the quantum meruit claim she actually presented against the estate. O’Dea urges that because the real “claim” on which Litzenburg ultimately, recovered was never presented to…”

Barry & Sewall Indus. Supply Co. v. Est. of Barry, 910 P.2d 657 (Ariz. Ct. App. 1996). · cites it 8× “” The trial court found, and the parties agree, that the A.R.S. section 14-3803(A) four-month period for presenting claims does not apply in this case because the corporation, a known creditor, was not notified that it needed to present its claim within that period.”

Matter of Est. of Levine, 700 P.2d 883 (Ariz. Ct. App. 1985). · cites it 4× “, and particularly A.R.S. § 14-3803, which provides: *188 “A.”

Stewart v. Travers, 965 P.2d 67 (Ariz. Ct. App. 1998). · cites it 3× “section 14-3803. The second motion argued the petition was untimely under Rule 60(c) of the Arizona Rules of Civil Procedure.”

Samaritan Health Sys. v. Caldwell, 957 P.2d 1373 (Ariz. Ct. App. 1998). · cites it 7× “section 14-3803 is restricted to claims against the decedent’s estate; nothing limits a creditor’s right to pursue a claim against a decedent’s joint obligor.”

Matter of Est. of Kopely, 767 P.2d 1181 (Ariz. Ct. App. 1988). · cites it 2× “In the underlying tort action, Winters’ answer to Fahoum’s complaint raised the defense that Fahoum had not filed a timely notice of claim as required by A.R.S. § 14-3803. Winters made and renewed motions to dismiss, objected to the form of judgment, and filed a motion for new…”

Show all 30 citing cases →

— Ariz. Rev. Stat. § 14-3803(A) — 13 cases

Ader v. Est. of Felger, 375 P.3d 97 (Ariz. Ct. App. 2016). “The primary issue presented in this appeal requires us to interpret A.R.S. § 14-3803 and A.R.S. § 14-3108 to determine whether Ader’s claims against the Estate are time-barred because no probate proceeding was initiated in Arizona within two years following Dan Felger’s death.”

Realty Assocs. v. Valley Nat'l Bank, 738 P.2d 1121 (Ariz. Ct. App. 1986). “The applicable Arizona statute is A.R.S. § 14-3803(A) which provides: A. All claims against a decedent’s estate which arose before the death of the decedent, including claims of the state and any subdivision thereof, whether due or to become due, absolute or contingent,…”

Evitt-Thorne v. Hiatt (In re Evitt), 429 P.3d 1146 (Ariz. Ct. App. 2018). “Accordingly, and for reasons that follow, we affirm the superior court's ruling barring Judith Evitt-Thorne's claim against her ex-husband's estate as time-barred under A.R.S. § 14-3803. FACTS AND PROCEDURAL BACKGROUND ¶ 2 Evitt-Thorne and Charles Evitt divorced in 1987.”

Est. of Page v. Litzenburg, 865 P.2d 128 (Ariz. Ct. App. 1993). “The issue is whether Litzenburg’s oral contract claim, upon which she recovered, materially varied from the quantum meruit claim she actually presented against the estate. O’Dea urges that because the real “claim” on which Litzenburg ultimately, recovered was never presented to…”

In Re Est. of Van Der Zee, 265 P.3d 439 (Ariz. Ct. App. 2011). “§ 14-3803(A)(2). For purposes of our review, we assume without deciding that Siebe is a known creditor who should have been served written notice, so he had at least two years pursuant to AR.”

— Ariz. Rev. Stat. § 14-3803(A)(1) — 7 cases

Academy Life Ins. v. Odiorne, 797 P.2d 727 (Ariz. Ct. App. 1990).

Flynn v. Olsen (Ariz. Ct. App. 2021).

Bmo v. Espiau (Ariz. Ct. App. 2021).

— Ariz. Rev. Stat. § 14-3803(A)(2) — 2 cases

Barry & Sewall Indus. Supply Co. v. Est. of Barry, 910 P.2d 657 (Ariz. Ct. App. 1996). “” The trial court found, and the parties agree, that the A.R.S. section 14-3803(A) four-month period for presenting claims does not apply in this case because the corporation, a known creditor, was not notified that it needed to present its claim within that period.”

— Ariz. Rev. Stat. § 14-3803(B) — 8 cases

Samaritan Health Sys. v. Caldwell, 957 P.2d 1373 (Ariz. Ct. App. 1998). “section 14-3803 is restricted to claims against the decedent’s estate; nothing limits a creditor’s right to pursue a claim against a decedent’s joint obligor.”

Knott v. Vachal, 752 P.2d 39 (Ariz. Ct. App. 1988).

— Ariz. Rev. Stat. § 14-3803(B)(1995) — 1 case

— Ariz. Rev. Stat. § 14-3803(C) — 4 cases

Gordon v. Est. of Brooks, 397 P.3d 1040 (Ariz. Ct. App. 2017).

Bmo v. Reid (Ariz. Ct. App. 2015).

— Ariz. Rev. Stat. § 14-3803(C)(2) — 5 cases

Moore v. Montes, 529 P.2d 716 (Ariz. Ct. App. 1974).

Matter of Est. of Chase, 609 P.2d 85 (Ariz. Ct. App. 1980).

Chase v. White, 609 P.2d 85 (Ariz. Ct. App. 1980).

Bmo v. Espiau (Ariz. Ct. App. 2021).

— Ariz. Rev. Stat. § 14-3803(D) — 1 case

Pargman v. Vickers, 96 P.3d 571 (Ariz. Ct. App. 2004). “Section 14-3803(D) states: "This section does not affect or prevent any of the following: .”

— Ariz. Rev. Stat. § 14-3803(D)(1) — 1 case

Arizona Health Care Cost Containment Sys. v. Allen, 173 P.3d 448 (Ariz. Ct. App. 2007). “A.R.S. § 14-3803; see also Harter v. Lenmark, 443 N.”

— Ariz. Rev. Stat. § 14-3803(D)(2) — 1 case

Pargman v. Vickers, 96 P.3d 571 (Ariz. Ct. App. 2004). “Section 14-3803(D) states: "This section does not affect or prevent any of the following: .”

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