Aryeh v. Canon Business Solutions, Inc

In Aryeh v. Canon Business Solutions, Inc. (2013) 55 Cal.4th 1185, the California Supreme Court summarized the law governing limitations periods. The statute of limitations begins running "from the moment a claim accrues." (Ibid.) A "'cause of action accrues "when it is complete with all of its elements" -- those elements being wrongdoing, harm, and causation.' This is the 'last element' accrual rule: ordinarily, the statute of limitations runs from 'the occurrence of the last element essential to the cause of action.'" (Ibid.) In the interests of equity, "exceptions to and modifications of" this rule may alter "either the initial accrual of a claim, the subsequent running of the limitations period, or both." (Aryeh, supra, 55 Cal.4th at p. 1192.) Three of these doctrines are relevant here. First, the discovery rule "'postpones accrual of a cause of action until the plaintiff discovers, or has reason to discover, the cause of action.'" (Ibid.) Second, the continuing violation doctrine "aggregates a series of wrongs or injuries for purposes of the statute of limitations, treating the limitations period as accruing for all of them upon commission or sufferance of the last of them." (Ibid.) Third, under the theory of continuous accrual, "a series of wrongs or injuries may be viewed as each triggering its own limitations period, such that a suit for relief may be partially time-barred as to older events but timely as to those within the applicable limitations period." (Ibid.)