Reed v. Real Detective Publishing Co
In Reed v. Real Detective Publishing Co., 63 Ariz. 294, 299, 306, 162 P.2d 133, 136, 139 (1945) the court addressed whether a libel claim survived the defendant's death and determined that "an injury . . . which affects the sensibilities is equally an injury to the person as an injury to the body would be."
The court noted, however, that the phrase "injury to person" emphasizes the word "person" as a noun, which relays greater importance on "a natural body, or perhaps a body corporate, and the injuries contemplated are injuries to that body." Id. at 301, 162 P.2d at 137.
(noting that "the expression 'injury to person' is clearly more restrictive than the term 'personal injuries' employed in the act under consideration, and is to be distinguished therefrom").
As a result, libel, which besmirches character or reputation, is not an injury to person for purposes of determining the applicable statute of limitations. Id. at 301-02, 162 P.2d at 137.