What is the applicable statute of limitations for an action brought by a defendant who is serving a life term in prison?

In actions where the federal court borrows the state statute of limitations, the court should also borrow all applicable provisions for tolling the limitations period found in state law. See Hardin v. Straub, 490 U.S. 536, 539, 109 S.Ct. 1998, 2000 (1989). Under California's Code of Civil Procedure, 352.1(a), "[i]f a person entitled to bring an action, . . . is, at the time the cause of action accrued, imprisoned on a criminal charge, or in execution under the sentence of a criminal court for a term less than for life, the time of that disability is not a part of the time limited for the commencement of the action, not to exceed two years." Thus, if a prisoner is not serving a life term, he/she is subject to a two-year tolling of the statute of limitations, resulting in a four-year statute of limitations. However, if a prisoner is serving a life term, he/she is not eligible for tolling as a prisoner, and the statute of limitations is only two years.