The following excerpt is from Kaufman v. Mutual Life Ins. Co. of New York, 108 F.3d 1385 (9th Cir. 1997):
California applies a four year statute of limitations to breach of contract claims. Cal.Code Civ.Proc. 337. A cause of action for breach of contract generally accrues at the time of breach. Whorton v. Dillingham, 202 Cal.App.3d 447, 456 (1988). The Kaufmans' breach of contract claim is that Mutual breached its contractual obligation under the group policy to provide them with a conversion policy containing more favorable terms. The district court held that if any such breach occurred, it occurred when Mutual issued the allegedly deficient conversion policy in 1988, approximately six years before the Kaufmans filed their complaint on August 9, 1994.
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