The One-Action Rule Nightmare

13 Pages Posted: 1 Sep 2015

See all articles by Roger Bernhardt

Roger Bernhardt

Golden Gate University - School of Law

Date Written: January 2015


Critique of California’s One Action Rule in mortgage foreclosures and its sanction effect.

Keywords: one action rule, foreclosure, sanction effect, First Calif Bk v McDonald

Suggested Citation

Bernhardt, Roger, The One-Action Rule Nightmare (January 2015). Available at SSRN: or

Roger Bernhardt (Contact Author)

Golden Gate University - School of Law ( email )

536 Mission Street
San Francisco, CA 94105
United States

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