Arizona Management Corp. v. Kallof
In Arizona Management Corp. v. Kallof, 142 Ariz. 64, 67, 688 P.2d 710, 713 (App. 1984), ARL's primary authority, the court concluded that a cause of action for attorney malpractice based on a defective settlement agreement he had drafted accrued "on the date the settlement agreement was entered into," not later when the validity of an underlying lease agreement was "judicially established."
As the court in Commercial Union pointed out, however, the plaintiff's damage in Kallof "was not only immediate and appreciable, it was 'readily apparent'" before the litigation. Commercial Union, 183 Ariz. at 256, 902 P.2d at 1360, quoting Kallof, 142 Ariz. at 68, 688 P.2d at 714.