HSL Linda Gardens Properties, Ltd. v. Freeman
In HSL Linda Gardens Properties, Ltd. v. Freeman, 176 Ariz. 206, 859 P.2d 1339 (App. 1993), the Court held that because the breach of a covenant not to sell land with encumbrances need not always cause damage, it would be "senseless on the facts of that case" to apply the general rule that a cause of action in contract accrues from the time of breach. Id. at 208, 859 P.2d at 1341.
Rather, the Court held that the cause of action accrues for purposes of the limitations period either from the date the plaintiff discovered or reasonably should have discovered the breach or from the time the plaintiff was damaged by the breach. See id.