Nolde v. Frankie
In Nolde v. Frankie, 192 Ariz. 276, 281,20, 964 P.2d 477, 482 (1998), the Arizona Supreme Court addressed equitable estoppel to prevent a defendant from raising a statute of limitations defense:
In determining whether a defendant is equitably estopped from asserting the statute of limitations defense based on inducement to forbear filing suit, a trial court must determine:
(1) whether the defendant engaged in affirmative conduct intended to cause the plaintiff's forbearance;
(2) whether the defendant's conduct actually caused the plaintiff's failure to file a timely action;
(3) whether the defendant's conduct reasonably could be expected to induce forbearance;
(4) whether the plaintiff brought the action within a reasonable time after termination of the objectionable conduct.