14.17.2 Accrual of Breach-of-Contract Claims.

• Jurisdiction: Arizona

14.17.2 Accrual of Breach-of-Contract Claims. The rule on accrual of a breach-of-contract action against an insurance producer differs from the rule in negligence cases. In the context of contractual breach, “[t]he traditional construction of [the] rule has been that the [statute] of limitations begins to run when the act upon which legal action is based took place, even though the plaintiff may be unaware of the facts underlying his or her claim.”²⁴¹ The court in Premium Cigars held that because Premium Cigars’ alleged damages were “open and obvious,” the traditional breach-of-contract rule, rather than...