California, United States of America
The following excerpt is from Brumfield v. Choi, E066190 (Cal. App. 2017):
Renter contends her case is not time-barred because the criminal prosecution was a continuing violation. "[T]he theory of continuous accrual . . . is a response to the inequities that would arise if the expiration of the limitations period following a first breach of duty or instance of misconduct were treated as sufficient to bar suit for any subsequent breach or misconduct; parties engaged in long-standing misfeasance would thereby obtain immunity in perpetuity from suit even for recent and ongoing misfeasance." (Aryeh v. Canon Business Solutions, Inc. (2013) 55 Cal.4th 1185, 1198.)
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