California’s one-action rule—legislatively misconceived at its creation, consistently misinterpreted by the judiciary, and capable of generating unpredictable and destructive consequences for practitioners—has been put on display again in First Cal. Bank v McDonald (2014) 231 CA4th 550. The decision also warns lender’s counsel that nonchalantly being helpful to a borrower can be suicidal.
Bernhardt, Roger, "The One Action Rule Nightmare" (2015). Publications. 693.