California, United States of America
The following excerpt is from Mikaelian v. City of Goleta, 2d Civil No. B191693 (Cal. App. 9/20/2007), 2d Civil No. B191693 (Cal. App. 2007):
Mikaelian asserts his claims are not subject to Government Code section 65009 because he is alleging violations of due process and equal protection. This argument has been made and rejected in numerous cases. As stated in Hensler v. City of Glendale, supra, 8 Cal.4th 1, 23, "`[T]he nature of the right sued upon and not the form of action nor the relief demanded determines the applicability of the statute of limitations under our code.'"
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