Section 14.21 Accrual of Action for Limitations and Venue
| Library | Tort Law 2016 |
F. (§14.21) Accrual of Action for Limitations and Venue
A cause of action for wrongful death "accrues" in two separate and distinct senses. As to time, it "accrues," for calculating the statute of limitations, when the death occurs. With respect to venue, however, it "accrues" at the place where the wrong was committed regardless of where death ensues. Dzur v. Gaertner, 657 S.W.2d 35 (Mo. App. E.D. 1983).
Two cases in 2015 reached widely varying results on the subject of estoppel and accrual, as follows:
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