California, United States of America
The following excerpt is from Green v. Zissis, 5 Cal.App.4th 1219, 7 Cal.Rptr.2d 406 (Cal. App. 1992):
A cause of action on a judgment accrues when "the judgment has become final either upon expiration of the period within which an appeal may be taken, or, if an appeal is taken, upon the issuance of the remittitur when the judgment has been affirmed." (Hoover v. Galbraith (1972) 7 Cal.3d 519, 525-526, 102 Cal.Rptr. 733, 498 P.2d 981.) Plaintiff herein obtained a judgment in May 1977. Accrual of plaintiff's cause of action occurred upon the non-appeal of this concededly valid final judgment. Nevertheless, the ten year statute of limitations period prescribed by section 337.5 did not begin to run because defendant was then absent from the state and has remained absent to this day. (Code Civ.Proc., 351.)
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