Law Firm Defense Blog

State Supreme Court clarifies statute of limitations for non-client claims against attorneys

06/12/2025 | by Christopher R. Blazejewski

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Law Firm Defense Blog

State Supreme Court clarifies statute of limitations for non-client claims against attorneys

By Christopher R. Blazejewski on June 12, 2025

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 their clients. Instead, such claims are governed by the applicable statute of limitations for the underlying cause of action- in the case of the malicious prosecution claim at issue in Escamilla, the two-year period under § 335.1. The ruling potentially impacts a wide range of third-party claims against attorneys, creating significant implications for how California attorneys assess risk and navigate potential liabilities to non-clients.

Click here to read the full article in The Daily Journal.

Christopher R. Blazejewski – Partner

Christopher R. Blazejewski represents businesses, law firms, and individuals in complex commercial litigation, legal malpractice defense, and business disputes.