liens upon real estate.” Former Cal. Const. Art. VI, § 5, quoted in Witkin, California Procedure, § 792. The broader definition set forth in § 392(a) applies in this case. Under that definition, venue is laid in the county where the real property is situated in the following types of actions: “(1) For the recovery of real property, or of an estate or interest therein, or for the determination in any form, of that right or interest, and for injuries to real property. (2) For the foreclosure of all liens and mortgages on real property.” Cal.Code Civ. Proc. § 392(a). The former constitutional provision treated the local action doctrine as a question of subject matter jurisdiction; § 392, by contrast, treats it as a venue issue. Compare Fritts v. Camp, 94 Cal. 393, 397-98, 29 P. 867 (1892) (<HOLDING>) with Nelson v. Crocker National Bank, 51
holding that only courts in the county where property was situated had jurisdiction to hear an action concerning the property holding that an action for consequential damages to property whether the action is brought in contract or in tort is an action for injury to property within the threeyear statute of limitations holding that the superior court had no jurisdiction over the division of marital property when the district court had properly invoked jurisdiction over the property holding that spouse could not claim exemption in property that was only property of other spouses estate holding that plaintiffs may have a property interest in real property