California, United States of America
The following excerpt is from Bevill v. Zoura, 27 Cal.App.4th 694, 32 Cal.Rptr.2d 635 (Cal. App. 1994):
Additionally, a three-day notice to pay or quit must be served within "one year after the rent became due." ( 1161, subd. 2; see Cal-American Income Property Fund IV v. Ho., supra, 161 Cal.App.3d at p. 585, 207 Cal.Rptr. 532.) If a landlord waits over one year to sue for unpaid rent, the landlord is limited to collecting such rent in an ordinary breach of contract action, "with all the delays that remedy normally involves and without restitution of the demised property." (Ibid.)
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