Tsemetzin v. Coast Federal Savings & Loan Assn

In Tsemetzin v. Coast Federal Savings & Loan Assn. (1997) 57 Cal.App.4th 1334, the court noted that "periodic monthly rental payments called for by a lease agreement create severable contractual obligations where the duty to make each rental payment arises independently and the statute begins to run on such severable obligations from the time performance of each is due." (Id. at p. 1344.) Thus, the court held, an action to recover unpaid installments must be brought within the limitations period after the particular installment becomes due. (Ibid.)