Is the statute of limitations extended under continuing violation doctrine or theory of continuous accrual?

California, United States of America


The following excerpt is from Kuba v. Seaworld, LLC, D064457 (Cal. App. 2015):

We are also unpersuaded the statute of limitations is extended under either the continuing violation doctrine or the theory of continuous accrual. "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." (Aryeh v. Canon Business Solutions, Inc. (2013) 55 Cal.4th 1185, 1192 (Aryeh).) The doctrine does not apply where, as here, the alleged wrong was discrete and independently actionable and it was not necessary for a series of harms to accumulate for the alleged wrong to become apparent. (Id. at p. 1198.)

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