Hennard

facts addressing the statute-of-limitations issue. Hennard filed a third amended complaint a few weeks later. In it, Hennard alleged that he did not learn that it was Cook who had taken the screenshot of his medical records until APHCV gave him a copy of its final investigative report in December 2019. APHCV again demurred. The trial court concluded that Hennard knew of the facts underlying the causes of action in his complaint no later than April 2017 and was thus required to file his complaint by April 2018. Because he did not sue APHCV until January 2020, his causes of action were barred by the statute of limitations. The court accordingly sustained APHCV’s demurrer, this time without granting leave to amend.

1 Statutory references are to the Code of Civil Procedure.

DISCUSSION

Hennard contends section 340.5’s one-year statute of limitations does not bar his causes of action against APHCV because he discovered the factual basis for those actions in December 2019—rather than in April 2017, as the trial court found—and filed his complaint one month later. We disagree. “Generally speaking, a cause of action accrues at ‘the time when the cause of action is complete with all…