Does the statute of limitations apply to a claim of breach of fiduciary duty?

Second, Barbara asserts that Family Code section 1101 only applies to a claim of breach of fiduciary duty. But the section is not so limited, and a claim does not have to name Family Code section 1101, subdivision (b), in order to be governed by it, as illustrated by Patrick v. Alacer Corp. (2011) 201 Cal.App.4th 1326. There, the court held that a widow's declaratory relief claim regarding her community property interest in a trust " 'essentially arises out of Family Code 1101,' " and therefore no statute of limitations applied. (Patrick v. Alacer Corp., supra, 201 Cal.App.4th at pp. 1334, 1337.)