Cited by

(the continuing-tort doctrine did not apply because “each claimed act is a separate assault causing separate as well as cumulative injury”).

§§ 12-502 (if action accrues while person is a minor, statute of limitations begins to run after person turns eighteen); 12-542(1) (two-year statute of limitations for personal injury claims); -12, 414 (App. 1996) (two-year statute of limitations applied to personal injury claims stemming from sexual abuse occurring from 1970 to 1992).

ed wrongful acts,” may be treated as a continuing harm, particularly where “any one of 4 DAVID-RYNN, et al. v. UHS OF PHOENIX, et al. Decision of the Court [the wrongful acts] likely was insufficient by itself to support the claim.” -72, ¶ 9, ¶15 (App. 2016); (holding that the continuing-tort doctrine did not apply because “each claimed act is a separate assault causing separate as well as cumulative injury”).

this court declined to apply a "continuing tort” theory to a woman’s claim that she was repeatedly sexually assaulted by her father.

v. Donahue, 3 COMMERCE/CRA v. ZINKE et al Decision of the Court

The “continuing tort” rule provides that, “under certain conditions a tort is continuous, and in such cases the limitations period does not commence until the date of the last tortious act.” (dicta; rejecting application of rule to repeated sexual assault claims).

1985) P.2d 875 (App. 1996), as supportive of the argument that bad faith is a continuous tort.

” but “must at least possess a minimum requisite of knowledge sufficient to identify that a wrong occurred and caused injury.” Doe, , 955 P.2d at 961 ; see also Stulce, , 3 P.3d at 1010 (“[A] cause of action accrues when a plaintiff discovers or reasonably should have discovered the injury was caused by the defendant’s negligent conduct.”); , (cause of action accrued as matter of law when plaintiff began treatment at sexual abuse center, showing she “had reason to know her father’s abuse [had] c

¶ 12 In an appeal from summary judgment, we “determine de novo whether genuine issues of material fact exist and whether the trial court correctly applied the law.”

(stating' that estoppel does not apply in the absence of evidence of “concealment, a specific threat or demonstrable duress”).

the claimant knows, or by the exercise of reasonable diligence should know, that the defendant harmed [him or] her,” and “it is not necessary for a claimant to know all the facts for the statute to begin to run; rather, all that is required is that he [or she] know enough facts as would prompt *178 a reasonable person to investigate and discover the full extent of the claim.”); , quoting Mayer, 14 Ariz.App.

Unlike Florez, Doe, , there are unresolved factual issues in this case as to whether plaintiff knew or by the exercise of reasonable diligence should have known, more than two years before filing suit, that Danforth or anybody else had molested her.