California, United States of America
The following excerpt is from Norgart v. Upjohn Co., 21 Cal. 4th 383, 21 Cal.4th 383, 87 Cal.Rptr.2d 453, 981 P. 2d 79 (Cal. 1999):
Viewing the matter thus, we believe that, at least as a usual matter, the general rule for defining the accrual of a cause of action should govern a cause of action for wrongful death. That means that, at least as a usual matter, the date of accrual of a cause of action for wrongful death is the date of death. ( Larcher v. Wanless (1976) 18 Cal. 3d 646, 656-657 [135 Cal. Rptr. 75, 557 P.2d 507].) For it is only on the date of death that a wrongful death cause of action becomes complete with all of its elements, which, as stated, include (1) a "wrongful act or neglect" on the part of one or more persons that (2) "cause[s]" (3) the "death of [another] person" (Code Civ. Proc., 377.60).
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