Roger E. Smith, Inc. v. SHN Consulting Engineers & Geologists, Inc.

Opinion

PARRILLI, J.

Which statute of limitations applies to a general contractor’s claims against an architect and construction manager for economic losses sustained due to their alleged professional negligence during construction? Instead of the two-year statute governing claims for breach of an oral contract (Code Civ. Proc., § 339, subd. 1), the general contractor in this case urges us to apply the four-year statute of limitations for patent deficiencies in construction (Code Civ. Proc., § 337.1). We conclude that Code of Civil Procedure section 337.1 does not encompass such claims and…