Under CCP 352.1, a prisoner serving a sentence for a term less than for life is entitled to toll the statute of limitations during the sentence—up to a maximum of two years. This decision holds that “a term less than for life” excludes only a life sentence without possibility of parole. Thus, plaintiff, a prisoner serving a sentence for life with possibility of parole, was entitled to two-year tolling of the statute of limitations under section 352.1.
California Court of Appeal, Fifth District (Kane, Acting P.J.); July 1, 2016; 2016 WL 3574026