Can you sue for fiduciary breach 10 years after dissolution?

Potentially yes, but a claim for breach of fiduciary duty arising from an old business relationship is usually time-barred if it accrued more than four years ago, and the answer turns on when the claim accrued and whether tolling or a later-discovered concealment theory applies. In California, the baseline limitations period for breach of fiduciary duty is generally four years under Cal. Code Civ. Proc. § 343, though if the gravamen is fraud/constructive fraud the three-year fraud period may apply. Thomson v. Canyon, 198 Cal. App. 4th 594 (2011)[1][2]

Bottom line

A former business partner cannot usually sue 10+ years after the business dissolved unless one of the following is true:

The breach occurred later than dissolution and the cause of action did not accrue until within the last four years; or
The breach was concealed and the plaintiff can invoke delayed discovery/tolling; or
A different theory or duty applies that has a later accrual date.

If the only relevant misconduct happened at or before dissolution more than 10 years ago, a California court would very likely find the claim untimely under Cal. Code Civ. Proc. § 343. Thomson v. Canyon, 198 Cal. App. 4th 594 (2011)[2]

Governing California limitations rules

“An action for relief not hereinbefore provided for must be commenced within four years after the cause of action shall have accrued.” Cal. Code Civ. Proc. § 343[3]

California authority applied in the materials confirms:

Nonfraudulent breach of fiduciary duty: generally four years under Cal. Code Civ. Proc. § 343. Thomson v. Canyon, 198 Cal. App. 4th 594 (2011)[2]
Fraudulent/constructive fraud-based breach of fiduciary duty: often treated under the three-year fraud statute. Thomson v. Canyon, 198 Cal. App. 4th 594 (2011)[2]
California guidance also recognizes that one cannot evade the shorter limitations period by artful pleading. [1][1]

Practical application to a 10-year-old dissolved business

Likely barred

If the alleged breach was tied to the operation, winding up, accounting, asset diversion, or disclosure obligations during dissolution, and those facts were knowable more than four years ago, the claim is likely barred.

Potentially still viable

A claim may still be viable if the plaintiff can plead and prove:

the partner continued to owe and breach fiduciary duties after dissolution in connection with winding up or concealed transactions;
the plaintiff did not discover and could not reasonably have discovered the breach until recently; or
there was fraudulent concealment that tolled the statute.

Key issue: accrual, not dissolution date alone

The dispositive question is not simply whether the business dissolved more than 10 years ago. It is when the cause of action accrued. A fiduciary-duty claim accrues when the plaintiff has suffered damage from the breach, subject to discovery/tolling principles. Thomson v. Canyon, 198 Cal. App. 4th 594 (2011)[2]

Short answer for a California case

Yes, a former partner could file suit in theory, but in most cases involving conduct tied to a dissolution more than 10 years ago, the claim would be time-barred unless delayed discovery or fraudulent concealment can be established.

If you want, I can also give you a California-specific statute-of-limitations checklist for partner fiduciary-duty claims or help analyze a fact pattern for accrual and tolling.