The following excerpt is from Haupt v. Dillard, 17 F.3d 285 (9th Cir. 1994):
Venegas v. Wagner, 704 F.2d 1144 (9th Cir.1983), upon which the district court relied, is not to the contrary. Venegas stands only for the proposition that, when a plaintiff alleges violation of his right to a fair trial and that violation resulted in a conviction, the conviction is the primary injury and the statute of limitations does not begin to run until the primary injury has occurred. Id. at 1146.
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