A case must have a defined cause of action accrual date, according to the 2024 Supreme Court case. Corner Post, Inc. v. Board of Governors, 603 U.S. (2024). The cause of action accrues when the plaintiff has a complete and present cause of action, which means they can file a lawsuit and get relief. See Id. The Supreme Court has determined that a claim accrues "when the plaintiff has a complete and present cause of action," and can file suit and obtain rehef. Wallace v. Kato, 549 U.S. 384, 388 (2007). The Court's precedent treats this definition of accrual as the "standard rule for limitations periods." See Id.

Accordingly, here the Court must [first] decide when a claim brought under O.C.G.A. § 9-3-25 "accrues" for purposes of the provision, whereas O.C.G.A. § 9-3-25 requires that "all actions upon open account, or for the breach of any contract not under the hand of the party sought to be charged, or upon any implied promise or undertaking shall be brought within four years after the right of action accrues."

In this case, the question presented that lingers, and which is left to be determined, is when exactly, specifically on what date, did the Petitioner's breach of oral contract claim accrue under the law, if not on July 5, 2018?

The District Court worked backwards from the case's November 4, 2022 filing date to determine a cause of action accrual commencement cut-off date in the action of July 3, 2018, but failed to determine any specific date on which the Petitioner's breach of oral contract claim began to accrue. The United Stated Court of Appeals for the Eleventh Circuit affirmed the District Court's lack of specificity in finding(s).

Whether a cause of action accrual date for a breach of oral contract claim can be definitively determined under Georgia law when the specific date of accrual remains ambiguous