Cannon v. Hirsch Law Office
In Cannon v. Hirsch Law Office, 222 Ariz. 171, 177,19, 213 P.3d 320, 326 (App. 2009), the Court held that the Amfac rule (Amfac Distribution Corp. v. Miller) did not extend the accrual date of a legal malpractice claim that was based on a failure to timely object to the discharge of a bankruptcy debtor and commence adversary proceedings. 222 Ariz. at 180,28-29, 213 P.3d at 329.
Cannon compared plaintiff's failure to commence adversarial proceedings in the bankruptcy court to "missing a statute of limitations that would initiate a civil action." Id. at28, 213 P.3d at 329.
There, however, the malpractice plaintiff did not attempt to remedy the error in the bankruptcy court. See id. at 174,4-5, 213 P.3d at 323.