Civil Procedure,
California Supreme Court
Jun. 6, 2025
State Supreme Court clarifies statute of limitations for non-client claims against attorneys
The California Supreme Court in Escamilla v. Vannucci clarified that the one-year statute of limitations under Code of Civil Procedure § 340.6 applies only to claims by clients or intended beneficiaries against attorneys, while claims by non-clients--such as third-party malicious prosecution actions--are governed by the statute of limitations for the underlying cause of action.
Christopher R. Blazejewski
Partner
Sherin and Lodgen LLP
Christopher R. Blazejewski is a partner at Sherin and Lodgen LLP, representing businesses, law firms, and individuals in complex commercial litigation, legal malpractice defense and business disputes. He defends national and regional law firms listed on the AmLaw 100 and NLJ 500 against legal malpractice, breach of fiduciary duty and other professional liability claims. For his business clients, Chris litigates contract, real estate, and intra-corporate disputes in a wide range of industries.
The California Supreme Court recently resolved the question of which statute of limitations applies when attorneys face claims brought by those outside the attorney-client relationship. In Escamilla v. Vannucci, 565 P.3d 702 (Cal. March 20, 2025), the court held that the one-year statute of limitations under Code of Civil Procedure § 340.6 does not apply to claims brought against attorneys by parties who were never their clients or the intended beneficiaries of ...
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