Supreme Court to hand down UCL statute of limitations opinion today: Aryeh v. Canon Business Solutions

Yesterday, in its notice of forthcoming filings, the Supreme Court announced that this morning it will hand down its opinion in Aryeh v. Canon Business Solutions, Inc., no. S184929.  When the opinion is posted online at approximately 10:00 a.m., is should be available at this link:

• Aryeh v. Canon Business Solutions, Inc., ___ Cal.4th ___ (2013)

These are the issues on review in the case, which was argued on December 4, 2012:

(1) May the continuing violation doctrine, under which adefendant may be held liable for actions that take place outside thelimitations period if those actions are sufficiently linked to unlawfulconduct within the limitations period, be asserted in an action underthe Unfair Competition Law (Bus. & Prof. Code, § 17200 et seq.)?

(2)May the continuous accrual doctrine, under which each violation of aperiodic obligation or duty is deemed to give rise to a separate causeof action that accrues at the time of the individual wrong, be assertedin such an action?

(3) May the delayed discovery rule, under which acause of action does not accrue until a reasonable person in theplaintiff's position has actual or constructive knowledge of factsgiving rise to a claim, be asserted in such an action?

With one justice dissenting, the Court of Appeal found each doctrine inapplicable.  Aryeh v. Canon Business Solutions, Inc., 185 Cal.App.4th 1159 (2010).  My earlier coverage of the case can be found in these two posts.  Links to the briefs are available here. 

I will hope to have more on the opinion in a later post.