California, United States of America
The following excerpt is from Brown v. City of Sacramento, 249 Cal.Rptr.3d 801, 37 Cal.App.5th 587 (Cal. App. 2019):
The City's reliance on Delaware State College v. Ricks (1980) 449 U.S. 250, 101 S.Ct. 498, 66 L.Ed.2d 431 for the proposition that "the pendency of a grievance ... does not toll the running of the limitations periods," misses the mark for similar reasons. (Id. at p. 261, 101 S.Ct. 498.) We need not decide whether the statute of limitations was tolled because we conclude that, under the Rules, the limitations period did not begin to run until sometime in late 2012, after the appeals process had run its course.
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