Eschenhagen v. Zika
In Eschenhagen v. Zika, 144 Ariz. 213, 696 P.2d 1362 (App. 1985), the Court held that a state applies its own statute of limitations in determining whether a foreign judgment is entitled to enforcement under the UEFJA. 144 Ariz. at 219, 696 P.2d at 1368.
In that case, enforcement of the foreign judgment at issue was precluded under either the five-year limitation statute for enforcement of judgments, A.R.S. 12-1551, or the four-year statute for enforcing foreign judgments, A.R.S. 12-544(3). Id.