Barrio v. San Manuel Div. Hosp
In Barrio v. San Manuel Div. Hosp., 143 Ariz. 101, 692 P.2d 280 (1984), the court held that a statute of limitations requiring a minor to bring a medical malpractice case while still underage violated the minor's fundamental rights. 143 Ariz. at 107, 692 P.2d at 286.
The statute at issue in Barrio required that a medical malpractice action on behalf of a minor under the age of seven be filed by the child's tenth birthday. Id. at 103, 692 P.2d at 282.
The court held the statute was unconstitutional because it did not "provide reasonable alternatives but rather abolished the action before it reasonably could be brought." Id. at 107, 692 P.2d at 286.