California, United States of America
The following excerpt is from Milliken v. City of South Pasadena, 158 Cal.Rptr. 409, 96 Cal.App.3d 834 (Cal. App. 1979):
Appellant filed her complaint on May 31, 1973. Respondents contend that since appellant was arrested on May 27, 1972, she did not file within the one-year limitation period for false arrest and imprisonment. (Code Civ.Proc., 340, subd. 3.) This argument has no merit, because appellant was not released from jail until May 31, 1972. Although a cause of action arose at the time of arrest and initial imprisonment, the statute of limitations did not commence to run until appellant's discharge from jail. (Collins v. County of Los Angeles, 241 Cal.App.2d 451, 455, 50 Cal.Rptr. 586; Annot. (1956) 49 A.L.R.2d 922; 35 C.J.S. False Imprisonment 49, p. 714.)
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