U.S. 999, 111 S.Ct. 558, 112 L.Ed.2d 565 (1990); Betts v. Board of Admin, of the Pub. Employees’ Ret. Sys., 21 Cal.3d 859, 148 Cal. Rptr. 158, 161, 582 P.2d 614, 617 (1978) (en banc) (stating that the right to a “substantial” or “reasonable” pension accrues on first day of employment); Petras v. State Bd. of Pension Trustees, 464 A.2d 894, 896 (Del.1983) (explaining that rights accrue when vesting occurs); Singer v. City of Topeka, 227 Kan. 356, 607 P.2d 467, 475 (1980) (similar to Petras, but adding that rights remain subject to “reasonable modification”); Sylvestre v. State, 298 Minn. 142, 214 N.W.2d 658, 666-67 (1973) (taking the position that an employee’s rights accrue on first day of employment); Baker v. Oklahoma Firefighters Pension & Ret. Sys., 718 P.2d 348, 353 (Okla.1986) (<HOLDING>); Leonard v. City of Seattle, 81 Wash.2d 479,
holding that rights accrue only when an employee vests recognizing that  1983 action does not accrue until conviction or sentence has been invalidated holding that fraud loss includes interest that the defendant promised would accrue holding that right to payment does not accrue until condition precedent has been fulfilled holding the claim of constructive discharge does not accrue until an employee resigns