What is the applicable statute of limitations on a beneficiary's action to reform the trust?

Pursuant to Getty v. Getty (1986) 187 Cal.App.3d 1159, 1168-1169, Code of Civil Procedure section 338, subdivision (d), is the applicable statute of limitations. Section 338, subdivision (d), imposes a three-year statute of limitations for "[a]n action for relief on the ground of fraud or mistake." The statute provides: "The cause of action . . . is not deemed to have accrued until the discovery, by the aggrieved party, of the facts constituting the fraud or mistake." In Getty the court concluded that the three-year statute of limitations on a beneficiary's action to reform a trust "began to run on the earliest date that [the beneficiary] can be charged with facts constituting the mistake." (Getty v. Getty, supra, 187 Cal.App.3d at p. 1169.) The beneficiary was charged with knowledge as of 1940. "Therefore, the period within which to seek reformation of the trust instrument expired in 1943." (Ibid.)