Day v. Wiswall
In Day v. Wiswall, 11 Ariz. App. 306, 464 P.2d 626 (1970), which was decided before the adoption of the Arizona's Uniform Enforcement of Foreign Judgments Act ("the UEFJA") in Arizona, the plaintiff received a favorable judgment from a California trial court in 1961. Id. at 308, 464 P.2d at 629.
That judgment was appealed in California and subsequently affirmed by the California Supreme Court in 1963. Id. In 1966, the plaintiff filed suit in Arizona seeking to enforce the California judgment. Id. at 309, 464 P.2d at 629.
On appeal, Division Two of this court ruled that the four-year statute of limitations set forth in A.R.S. 12-544(3) did not begin to run until the time to appeal the California judgment had passed or if appealed, its final determination on appeal had been issued. Id. at 313, 464 P.2d at 634.