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Hyland v. Hughes Aircraft Company2/26/2002
r three reasons: First, Hughes is estopped to rely on the statute of limitations because it misled Hyland regarding his rights under the Letter Agreement; second, the delayed discovery doctrine applies and it is a jury question whether Hyland was on inquiry notice under the circumstances; and third, the statute does not run against a trust beneficiary's claim to receive property held on his behalf. Respondents argue that Hyland's claims expired in 1988 or 1989; and even if they did not, the delayed discovery rule does not save plaintiff's claim because Hyland had a duty to investigate as soon as he suspected or should have suspected the Letter Agreement would not be honored. Furthermore, Hyland had the critical information he needed: the acquisition of Hughes and the funding of the LTIP. Respondents argue that no confidential relationship can be found which would support an estoppel because Hughes's statements were statements concerning its liability, not misstatements of fact. (See, e.g., Vu v. Prudential (2001) 26 Cal.4th 1142; Neff v. New York Life Ins. Co. (1947) 30 Cal.2d 165; Love v. Fire Insurance Exchange, supra, 221 Cal.App.3d 1136.)
A. Where the Facts Are Undisputed, We Review the Question of Whether the Statute of Limitations Has Run as a Matter of Law.
Where the evidence pertaining to a statute of limitations defense is not in conflict, the court may decide the question as a matter of law. (Estate of Fincher, supra, 119 Cal.App.3d at p. 351.) Along these lines, the date the cause of action accrues may similarly be a question of law if the facts are undisputed. (Slavin v. Trout (1993) 18 Cal.App.4th 1536, 1538.) In the instant case, all facts relating to Hyland's state of knowledge were within Hughes's purview and thus not subject to reasonable dispute by plaintiff; conversely, all facts relating to plaintiff's discovery of the Letter Agreement were within her purview and thus not subject to reasonable dispute by Hughes. Generally, statute of limitations issues raise questions of fact that must be tried, however, when the uncontradicted facts are susceptible of only one legitimate inference the question is one of law. (Jolly v. Eli Lilly & Co (1988) 44 Cal.3d 1103, 1112.) In the instant case, the essential facts were not in conflict; what was in conflict was their legal import. Based on the undisputed facts, we conclude the discovery rule exclusively governs the resolution of this issue, as the cause of action had not yet expired upon Hyland's death in 1989. Furthermore, because plaintiff was ignorant of the facts underlying her claim until she discovered them in 1996, she is entitled to the benefit of the discovery rule.
B. The Statute Began to Run in 1988 When the First Payments and/or Stock Distributions Were Made to Participants.
The statute of limitations begins to run on a claim "upon the occurrence of the last element essential to the cause of action." (Neel v. Magana, Olney, Levy, Cathcart & Gelfand (1971) 6 Cal.3d 176, 187.) In the case of a contract claim, that would be upon the defendant's failure to tender performance which was due. (Niles v. Louis H. Rapoport & Sons (1942) 53 Cal.App.2d 644, 651.) Contract claims, whether for damages or declaratory relief, have a limitations period of four years. (Code of Civ. Proc., § 337 [contract claims]; 3 Witkin, Cal. Procedure (4th ed. 1996) Declaratory Relief, § 625, p. 804 [declaratory relief actions have same statute of limitations as that of underlying claim, whether tort or contract].) The claim will accrue whether the plaintiff is aware of the cause of action or not. (Niles, supra, at p. 651.)
The claim in the instant case accrued when Hughes/GM breached the Letter Agreement b
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