What is the "primary right" of a plaintiff in a motor vehicle accident?

And again, it has been observed: "'As far as its content is concerned, the primary right is simply the plaintiff's right to be free from the particular injury suffered. . . . It must therefore be distinguished from the legal theory on which liability for that injury is premised: "Even where there are multiple legal theories upon which recovery might be predicated, one injury gives rise to only one claim for relief." . . . The primary right must also be distinguished from the remedy sought . . . .' [Citations.]" (Villacres v. ABM Industries Inc. (2010) 189 Cal.App.4th 562, 577.)