Crogan v. Crogan

STEELMAN, Judge.

Where claims arose in tort, the trial court did not err in applying a three-year statute of limitations to claims for fraud, duress, and undue influence. Where plaintiff’s claim for breach of contract arose pursuant to a contract under seal, the trial court erred in applying a three-year statute of limitations.

I. Factual and Procedural Background

Felicia Renee Crogan (plaintiff) and Jon Brent Crogan (defendant) were married on 23 March 1985. There were three children bom to the marriage.

Plaintiff and defendant separated on 1 October 2004. Defendant’s attorney prepared a…