Tornow v. Superior Court CA2/7
Prosecution for crimes involving fraud must begin within four years of the completion of the offense or the discovery of its commission, whichever is later. (Pen. Code, §§ 801.5, 803, subd. (c).) “Discovery,” however, does not require actual knowledge: “The crucial determination is whether law enforcement authorities or the victim had actual notice of circumstances sufficient to make them suspicious of fraud thereby leading them to make inquiries which might have revealed the fraud.” (People v. Zamora (1976) 18 Cal.3d 538, 571-572 (Zamora).) That is, law enforcement is held to a “standard of reasonable diligence.” (Id. at p. 572.)
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