Western Casualty & Surety Co. v. Evans
In Western Casualty & Surety Co. v. Evans, 130 Ariz. 333, 335, 636 P.2d 111, 113 (App. 1981) the Court recognized that the filing of a declaratory judgment action does not, per se, constitute an accrual of an action sufficient to start the limitations clock. Id. at 336, 636 P.2d at 114.
Instead, "for an action to accrue for limitation purposes, some event in the nature of a breach of contract" must occur. Id.
When a breach or actual injury does occur, a coercive cause of action may be brought and maintained even though declaratory relief has been requested. See Ariz. R. Civ. P. 57 (providing that judgment for declaratory relief is not precluded by "the existence of another adequate remedy").