Watkins v. Arpaio

OPINION

JOHNSEN, Judge:

¶ 1 Lee Watkins argues the superior court erred by dismissing on limitations grounds his claims against Maricopa County Sheriff Joe Arpaio for intentional infliction of emotional distress and false-light invasion of privacy. He argues the torts were “continuing wrongs” that did not finally accrue until less than a year before he filed his complaint. We hold that, under the circumstances, the statutes governing accrual and limitations of a claim against a public employee preclude application of the “continuing wrong” doctrine to save either of Watkins’s claims.

*170FACTS AND…