Lopez v. Sony Electronics, Inc., 234 Cal. Rptr. 3d 856

Dominique Lopez (born Apr. 13, 1999) alleged congenital birth defects caused by her mother’s workplace exposure to teratogenic/toxic chemicals at a Sony plant.
Lopez sued Sony on Jan. 6, 2012, while she was a minor.
Sony moved for summary judgment arguing the claim was time-barred under Cal. Code Civ. Proc. § 340.4 (six‑year limitations for prenatal/birth injuries with no tolling for minority).
Lopez contended her cause of action fell under § 340.8 (toxic exposure claims), which creates a two‑year accrual rule tied to discovery but is tolled during minority under § 352.
The trial court granted summary judgment under § 340.4; the Court of Appeal affirmed; the California Supreme Court granted review to resolve the conflict between § 340.4 and § 340.8.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Which statute of limitations governs prenatal injuries caused by toxic exposure: § 340.8 (toxic exposure) or § 340.4 (prenatal/birth injuries)?	Lopez: § 340.8 governs because it applies to "any civil action" based on hazardous exposure and includes discovery‑based accrual.	Sony: § 340.4 governs prenatal injuries; it is a specific, long‑standing statute prescribing a six‑year, non‑tolled period.	The Court held § 340.8 governs prenatal injuries caused by hazardous/toxic exposure because it is the later enactment with broad "any" language and contains specific exceptions but not § 340.4.
Effect of applying § 340.8 on minority tolling and timeliness of this suit	Lopez: § 340.8 is subject to tolling during minority (§ 352), so her 2012 suit (filed as a minor) is timely.	Sony: Applying § 340.8 would improperly nullify § 340.4’s no‑tolling rule for prenatal claims; implied repeal is disfavored.	The Court held § 340.8’s limitations are tolled during minority under § 352; applying § 340.8 did not produce absurd results and did not improperly repeal § 340.4 for non‑toxic prenatal injuries. Lopez’s suit was timely.

Young v. Haines, 41 Cal.3d 883 (Cal. 1986) (discusses statutes governing prenatal and birth injury claims and the discovery rule)
Norgart v. Upjohn Co., 21 Cal.4th 383 (Cal. 1999) (articulates common‑law delayed discovery rule for tort accrual)
Jolly v. Eli Lilly & Co., 44 Cal.3d 1103 (Cal. 1988) (delayed discovery accrual doctrine in toxic torts)
Nguyen v. Western Digital Corp., 229 Cal.App.4th 1522 (Cal. Ct. App. 2014) (applied § 340.8 to toxic exposure claims and recognized minority tolling)
State Dept. of Public Health v. Superior Court, 60 Cal.4th 940 (Cal. 2015) (principles for harmonizing conflicting statutes; rules for later enactments and specificity)
Even Zohar Constr. & Remodeling, Inc. v. Bellaire Townhouses, LLC, 61 Cal.4th 830 (Cal. 2015) (criteria for finding implied repeal and reconciling statutes)
Delaney v. Superior Court, 50 Cal.3d 785 (Cal. 1990) (interpretation of broad terms like "any")
Williams v. Los Angeles Metro. Transit Auth., 68 Cal.2d 599 (Cal. 1968) (tolling principles and protection of minors' rights)