Harrington v. Beauchamp Enters

In Harrington v. Beauchamp Enters., 158 Ariz. 118, 121, 761 P.2d 1022, 1025 (1988), a negligence and products liability case, id. at 119, 761 P.2d at 1023, the jury asked a question during deliberations concerning the statute of limitations, id. at 120, 761 P.2d at 1024. Apparently, a contract entered into evidence contained a one-year workmanship warranty. Id. The jury asked the trial court: "How many years is a contractor liable for defects in workmanship and materials . . . ? Contract reads one year. The Court want to know if another law forgoes the contract." Id. The trial court provided no clarifying instruction, and the jury returned a verdict for the defense. Id. Noting that "no limitations period, statutory or contractual, was at issue in the trial," id., our supreme court determined the trial court had erred by failing to respond to the jury's question, id. at 121, 761 P.2d at 1025.