There shall be commenced and prosecuted within two years after the cause of action accrues, and not afterward, the following actions:
1. For injuries done to the person of another including causes of action for medical malpractice as defined in §12-561.
2. For injuries done to the person of another when death ensues from such injuries, which action shall be considered as accruing at the death of the party injured.
Kenyon v. Hammer, 142 Ariz. 69, 688 P.2d 961 (1984). (An action against a doctor for the negligence of his nurse in wrongly recording the Rh factor of his maternity patient, resulting in the stillbirth of the infant, is not barred by three-year statute. The court held that the date of the injury determines the accrual of the cause of action. The date of injury is when the injury occurs and not the date on which the negligent act occurs.
DeBoer v. Brown, 138 Ariz. 168, 673 P.2d 912 (1983). (A cause of action for the misdiagnosis of a cancerous lesion as "wart" accrues, not at the time of the misdiagnosis, but at the time the lesion begins to grow, posing a greater danger or requiring more extensive treatment.)
Russo v. Diethrich, 126 Ariz. 522, 617 P.2d 30 (Ct. App. 1980). (Arizona does not recognize the rule under which the statute of limitations is tolled as long as the physician-patient relationship exists.)
Langager v. Lake Havasu Community Hosp., 688 F.2d 664 (9th Cir. 1982) , applying Arizona law. (Summary judgment was improper in view of the issue presented by the allegation that the patient, who had suffered a stroke while in the defendant hospital, first discovered two years afterward that hospital employees had altered the medical records, thus deliberately concealing the facts and preventing discovery of the injury, hence tolling the statute.)