Lowry v. Crandall

In Lowry v. Crandall, 52 Ariz. 501, 83 P.2d 1003 (1938), several creditors prematurely filed claims against the decedent's estate before the administrator had filed an inventory or given notice to creditors. Id. at 503, 83 P.2d at 1004. The administrator denied the claims. Id. After the administrator prepared an inventory and gave notice to creditors, an assignee of the claims resubmitted them to the administrator, who again rejected them. Id. About a month later, the assignee sued to establish the claims. Id. The estate argued the claims were time-barred because they were not brought within the statutory period after the date of the administrator's first denial. Id. The supreme court held that, although the claims were premature when first filed, the administrator validly exercised his authority to reject them. Id. Consequently, the claimant had to bring an action on the claim within the three months after the first rejection, the period prescribed by statute at the time. Id. at 504, 83 P.2d at 1004.