California, United States of America
The following excerpt is from Butcher v. Truck Insurance Exchange, 77 Cal. App.4th 1442, 92 Cal.Rptr.2d 521 (Cal. App. 2000):
In Budd v. Nixen (1971) 6 Cal.3d 195, the court held that the limitations period on the plaintiff's legal malpractice claim did not begin until plaintiff had suffered "appreciable harm." (Id. at p. 200.) "The mere breach of . . . duty," said the court, "causing only nominal damages, speculative harm, or the threat of future harm 3/4 not yet realized" normally "does not suffice to create a cause of action." (Ibid.)
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