Cal. Probate Code § 9351 : California Probate Code — Administration Of Estates Of Decedents — Claims In Litigation — Claim Where No Pending Action Or Proceeding — Commencing action against personal representative on cause of action against decedent Date: 31 Aug 2016 TEXT PDF Current through the 2016 Legislative Session An action may not be commenced against a decedent's personal representative on a cause of action against the decedent unless a claim is first filed as provided in this part and the claim is rejected in whole or in part. Ca. Prob. Code § 9351