In Deer Valley Unified Sch. Dist. v. Houser (McDonald), 214 Ariz. 293, 299,23, 152 P.3d 490, 496 (2007), the plaintiff alleged that her claim accrued in March 2005, and she filed a notice of claim in September 2005. 214 Ariz. at 294, 299-300,2, 23, 152 P.3d at 491, 496-97. The supreme court held that the notice was substantively defective and because the statutory time in which to file a proper claim had expired, the claim was barred. Id. at 296-97, 299,10-11, 23, 152 P.3d at 493-94, 496. Deer Valley relied on Falcon ex rel. Sandoval v. Maricopa County, 213 Ariz. 525, 527,10, 144 P.3d 1254, 1256 (2006), which held that if a notice of claim is not properly served within the statutory limits, a plaintiff's claim is barred by the statute and substantial compliance is insufficient. Falcon, 213 Ariz. at 527,10, 144 P.3d at 1256. However, Falcon only dealt with proper service of a notice of claim, not whether a premature claim satisfies the requirement. Id. at 526,2, 144 P.3d at 1255.