California, United States of America
The following excerpt is from Crouse v. Brobeck, Phleger & Harrison, 67 Cal.App.4th 1509, 80 Cal.Rptr.2d 94 (Cal. App. 1998):
2 The ruling would appear to be a nullity. Nothing in the summary judgment statute allows a single cause of action alleging legal malpractice to be separated into component acts with separate statute of limitations running on each discrete act. When a cause of action for malpractice alleges a single injury, the fact that the attorney's course of conduct involved discrete negligent acts or omissions does not create separate causes of action with a separate statute of limitations for each act or omission. (Cf. Panos v. Great Western Packing Co. (1943) 21 Cal.2d 636, 638, 134 P.2d 242 [where single injury alleged, different acts of negligence contributing to injury do not create separate causes of action].) Boatwright relies on Lilienthal & Fowler v. Superior Court (1993) 12 Cal.App.4th 1848, 16 Cal.Rptr.2d 458 to support his argument. However, in Lilienthal, separate statutes of limitation ran on different claims for malpractice because the claims arose from different services provided at different times involving separate and distinct unrelated transactions. (Id. at p. 1850, 16 Cal.Rptr.2d 458.)
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