California, United States of America
The following excerpt is from Christ v. Lipsitz, 160 Cal.Rptr. 498, 99 Cal.App.3d 894 (Cal. App. 1979):
The word "injury" in the statute includes not only the physical condition but also the negligent cause of the condition (Sanchez v. South Hoover Hospital, 18 Cal.3d 93, 99, 132 Cal.Rptr. 657, 553 P.2d 1129). It refers to the damaging effect of the alleged wrongful act and not to the act itself. No cause of action accrues until the patient suffers appreciable harm as a consequence of the alleged act of malpractice (Larcher v. Wanless, 18 Cal.3d 646, 656, fn. 11, 135 Cal.Rptr. 75, 557 P.2d 507).
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