Massachusetts Court Clarifies Statute of Repose Trigger for Multi-Phase Construction Projects

In D’Allesandro v. Lennar Hingham Holdings, LLC, C.A. No. 17-cv-12567-IT, 2019 U.S. Dist. LEXIS 185874, the United States District Court for the District of Massachusetts heard a case against a general contractor and its related entities involved in the construction of a multi-phase project. The court held that in this context, completion of the “improvement” triggering the six-year statute of repose for the plaintiffs’ negligence and breach of implied warranty claims was the whole project, rather than each individual phase.

Kyle Rice, an associate in the Subrogation Department, discusses the outcome of this case in Temple's Business Law Magazine, The Temple 10-Q.