SACRAMENTO, Calif. - Recent California Supreme Court case law shows that the Ninth Circuit U.S. Court of Appeals erred in previously finding that the statute of limitations in California unfair competition law (UCL) cases begins at the time of the violation, a federal judge held in an opinion posted Sept. 11 (Donald W. Irving, et al. v. Lennar Corp., et al., No. 12-290, E.D. Calif.; 2013 U.S. Dist. LEXIS 130095).