Arizona Court of Appeals Division One: No. 1 CA-CV 23-0744 Filed October 31, 2024
City of Chandler v. Roosevelt Water Conservation District
ISSUES:
- Whether the one-year statute of limitations in A.R.S. § 12-821 applies to actions by one public entity against another public entity, and, if so, whether the City of Chandler filed its action within the one-year limitations period.
- When does the statute of limitations on a breach of contract action accrue under A.R.S. § 12-821 if the defendant has both anticipatorily repudiated a contract and committed a material breach for non-performance?
DECISION: Reversed and remanded
- The court concluded that the one-year statute of limitations in A.R.S. § 12-821 does apply to actions by one public entity against another public entity: The statutory language overrides the common law nullum tempus doctrine that typically exempts public entities from statutes of limitations
- The court determined that Chandler’s claims were time-barred under the one-year statute of limitations.
Synopsis:
This case involves a dispute between the City of Chandler and the Roosevelt Water Conservation District over a water service agreement. The court examined whether the one-year statute of limitations in A.R.S. § 12-821 applies to actions between public entities and whether the nullum tempus doctrine exempts such actions from the statute of limitations. The court concluded that § 12-821 applies to all actions against public entities, including those brought by other public entities.
The court’s analysis provides important clarification on the application of statutes of limitations to public entities in Arizona. It emphasizes a textualist approach to statutory interpretation and demonstrates how legislative history and context can inform the understanding of statutory language. The decision also touches on important principles of contract law, particularly regarding the accrual of claims in cases of anticipatory repudiation and subsequent material breach.
Outcome of the Case:
The court reversed the superior court’s grant of summary judgment for Chandler and remanded the case.