What is the applicable statute of limitations for a claim of emotional trauma?

California, United States of America


The following excerpt is from Shipman v. Napa Cnty., A130817 (Cal. App. 2011):

Respondents also note that the acts of which appellants complain date back several years, and they argue that appellants failed to plead facts sufficient to demonstrate their claims were not barred by the applicable statute of limitations. Not so. Respondents do not assert the applicability of any statute of limitations except Code of Civil Procedure section 335.1 for "emotional trauma" and Code of Civil Procedure section 329.5 for relief from assessments for public improvements. As to Code of Civil Procedure section 335.1, appellants refer to emotional trauma in their pleading, but the prayer of their amended complaint does not seek recovery for emotional trauma. As to Code of Civil Procedure section 329.5, the statute provides a 30-day limitations period for attacking the validity of a chartered city's assessment against real property for public improvements.6 (Code Civ. Proc., 329.5; see Bliler v. City of San Diego (1976) 61 Cal.App.3d 530, 534-535 [public

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