State v. Mabery Ranch Co
In State v. Mabery Ranch Co., 216 Ariz. 233, 249,74, 165 P.3d 211, 227 (App. 2007), the Court addressed, in part, a plaintiff's slander of title claim for damages against the state in light of 12-821. 216 Ariz. at 248-49,68-75, 165 P.3d at 226-27.
The Court determined that the plaintiff's claim for damages was barred under 12-821, because "it is plain that Mabery was aware of its alleged damages more than a year prior to its filing of the counterclaim." Id. at 248,70, 165 P.3d at 226.
The court disagreed with the plaintiff's argument that its slander of title claim was a continuous wrong that "accrues each day." Id. at 249,73, 165 P.3d at 227.
The court recognized that "while slander of title may be a continuous wrong, limitations on a damages claim for slander of title begins to run when damages result." Id. at 249,74, 165 P.3d at 227.