Massachusetts Court Holds Statute of Repose Bars Certain Asbestos-Related Construction Claims

Many clocks with faded black background

Claims Arising Out of a Deficiency or Negligence in the Design, Planning, Construction and General Administration of Improvements to Real Property Among Those Affected

April 17, 2019
Timothy J. Keough & Rochelle Gumapac - White and Williams LLP

In Stearns v. Metropolitan Life Insurance Company, the Massachusetts Supreme Judicial Court (SJC) addressed whether the six-year statute of repose for improvements to real property applies to long-tail tort claims, such as those caused by exposure to asbestos. Reasoning that the language of § 2B is clear, unambiguous and unequivocal, the SJC held that Mass. Gen. Laws. c. 260 § 2B does in fact bar all tort claims arising out of a deficiency or neglect in the design, planning, construction or general administration of an improvement to real property filed after the expiration of the six-year repose period. Additionally, the court affirmed that the time limitations imposed by the statute of repose may not be tolled for any reason six years after either the opening of the improvement for use or the owner taking possession of the improvement for occupation upon substantial completion, whichever may occur first.

Reprinted courtesy of Timothy J. Keough, White and Williams LLP and Rochelle Gumapac, White and Williams LLP
Mr. Keough may be contacted at
Ms. Gumapac may be contacted at

You’re Only as Good as Those with Whom You Contract

Red pencil leaning on construction contract

If the other party to the contract simply decides not to perform it will be an expensive proposition to force compliance or be compensated for the monetary damage caused by such actions.

April 17, 2019
Christopher G. Hill - Construction Law Musings

I have been beating the drum of the need to have a solid construction contract as the basis for your construction project and contractor/subcontractor/supplier relationships. I have also emphasized that communication early and often is one of the best ways to assure a smooth project. However, the sad truth is that even with the best contract drafted with the assistance of an experienced construction attorney, if the other party to the contract simply decides not to perform, whether that is through unjustified non-payment or simple refusal to complete a scope of work without reason, it will be an expensive proposition to force compliance or be compensated for the monetary damage caused by such actions.

It is this often unmentioned truth relating to any contract, including those that construction professionals in Virginia deal with on a daily basis, that makes having a good knowledge of those with whom you plan to contract is key to a successful (read profitable) construction project. Of course be sure that any contractor or subcontractor you contract with has the basics of propoer insurance, the right experience and of course a contractor’s license with the proper specialty or specialties. These basics will get you most of the way to assuring that those that contract with you at least are responsible in business. Another key component, if you can find this information out, is the financial wherwithall of the other party. For a General Contractor, this means both sides of the equation: Owner and Subcontractors. For a Subcontractor, the key is the Contractor, but any other information you can get on the Owner is helpful (though this can be difficult) particularly in the face of a “pay if paid” clause.

Mr. Hill may be contacted at

Four Trends to Watch for the Construction Industry in 2019

April 17, 2019
Mike Sobolewski - Construction Executive

By most accounts, 2017 and 2018 were successful, but balanced, years for the industry. Many companies recognized the benefits of strong backlogs and growth in a number of the industry sectors, while also seeing challenges in cost containment, product availability, talent and preparing for an anticipated overall downturn.

Engineering and construction firms often are the hardest hit when economic conditions change. Some strategies that could help position construction firms for success include using technology to improve efficiencies, renegotiating contracts with clients and suppliers and using M&A to increase market share. Even with the best-laid plans, however, unanticipated political and economic events can require organizations to change course. Agile strategies are key to managing capital projects and infrastructure.

Reprinted courtesy of Mike Sobolewski, Construction Executive, a publication of Associated Builders and Contractors. All rights reserved.

SCOTUS, Having Received Views of Solicitor General, Will Decide Whether CWA Regulates Indirect Discharge of Pollutants Into Navigable Water Via Groundwater

Focus on grasses by sandy beach

The last arguments to be heard this term will take place on April 24, 2019.

April 17, 2019
Anthony B. Cavender - Gravel2Gavel

Prior to deciding whether to review an important February 1, 2018, U.S. Court of Appeals for the Ninth Circuit decision involving the jurisdictional reach of the Clean Water Act (CWA), Hawai’i Wildlife Fund, et al., v. County of Maui, the Supreme Court asked the Solicitor General for the views of the U.S. on the holdings of this case and the April 12, 2018 U.S. Court of Appeals for the Fourth Circuit decision, Upstate Forever, et al., v. Kinder Morgan Energy Partners, L.P., et al.

On February 19, the Supreme Court confirmed that certiorari was granted to Question 1 presented by the Petition,

Whether the CWA requires a permit when pollutants originate from a point source but are conveyed to navigable waters by a nonpoint source, such as groundwater. (33 U.S.C. § 1362 (12)

In County of Maui , the Ninth Circuit held that indirect discharges to navigable waters through groundwater may be subject to the Environmental Protection Agency’s (EPA) CWA the National Pollutant Discharge Elimination System (NPDES) permitting authority, and in Kinder Morgan, the Fourth Circuit held that such an indirect discharge may be subject to regulation under the CWA when there is a direct hydrological connection between the discharge into groundwater and the direct discharge into navigable, surface waters.

Mr. Cavender may be contacted at

OSHA Finalizes Rule on Crane Operator Qualification and Certification

Hook crane

Brad Hammock’s national practice focuses on all aspects of occupational safety and health law.

April 10, 2019
Bradford T. Hammock - Construction Executive

The Occupational Safety and Health Administration has finalized its long-awaited approach to crane operator qualification and certification. The rule, which has followed a tortuous road to completion, ends the agency’s multi-year effort to conclude its update of safety requirements related to crane and derrick use in construction.

The rule establishes a three-pronged approach to ensuring that crane operators can safely operate cranes:

  1. operator training for employees not yet certified to operate cranes;
  2. operator certification via four different permissible options; and
  3. employer evaluation of certified operators.

Construction employers with employees who operate cranes should assess their training, certification and evaluation programs now to ensure they are fully compliant with the new rule.

Reprinted courtesy of Bradford T. Hammock, Construction Executive, a publication of Associated Builders and Contractors. All rights reserved.

Santa Rosa Recreates Permitting, Construction System 'On the Fly'

April 10, 2019
Pam Radtke Russell - Engineering News-Record

As construction started gearing up late last year to rebuild some 3,000 homes in Santa Rosa burned by the 2017 Tubbs Fire, there were several challenges. One of the greatest was the shortage of concrete.

Ms. Russell may be contacted at

Dealing with Abandoned Property After Foreclosure

Words on page property taxes rent real estate utilities

Following the statutory procedures relating to abandoned property protects landlords from potential liability for an improper “conversion.”

April 10, 2019
Bremer Whyte Brown & O'Meara LLP

California landlords must follow very specific steps before disposing of property that is clearly abandoned, left on real estate which has been the subject of court proceedings such as eviction or foreclosure, or otherwise left behind. Following the statutory procedures relating to abandoned property protects landlords from potential liability for an improper “conversion.”

Former tenants/owners and others “reasonably believed” to be owners of the apparently abandoned personal property must be given proper written notice of the right to reclaim the abandoned property. The tenant is presumed to be the owner of any “records” remaining on the property. The California Code of Civil Procedure provides a template for such notice. The notice to be provided to former tenants/owners must be in “substantially” the same form provided in the California Code of Civil Procedure and must contain the following information:

  1. A description of the abandoned property in a manner reasonably adequate to permit the owner of the property to identify it;
  2. The location where the tenant can claim the property;
  3. The time frame that the tenant has to claim the property. The date specified in the notice shall be a date not less than fifteen (15) days after the notice is personally delivered or, if mailed, not less than eighteen (18) days after the notice is deposited in the mail;
  4. A statement that reasonable storage costs will be charged to the tenant/owner and the tenant/owner must pay those costs before claiming the property; and

Industry Practices Questioned After Girder Fractures at Salesforce Transit Center

Construction worker salute carrying girder

A brouhaha over the blame for the girder fractures that shuttered the three-story transit hub last Sept. 25.

April 10, 2019
Nadine M. Post - Engineering News-Record

Attendees of a recent presentation on the earthquake-resistant structure of San Francisco’s Salesforce Transit Center—intended to provide a safe haven when the Big One hits—lauded the engineering of the 4.5-block-long hollow tube that supports the 1.2-million-sq-ft “groundscraper.” But there also was much talk of the project’s black eye, as a consequence of brittle fractures of the bottom flanges of two bridge-like built-up plate girders that span 87 ft over Fremont Street.

Ms. Post may be contacted at

Trends in Commercial Real Estate Contractors Need to Know

April 10, 2019
James Segil - Construction Executive

Commercial real estate stakeholders are finding it more important than ever to upgrade their buildings’ infrastructure and embrace new technologies. However, it can be tough to distinguish between which tech trends are passing fads and those that are worth investing in. As tenant needs shift, making the right investments can greatly impact the long-term health and prosperity of a building and can help attract and retain tenants.

One of the biggest trends to look out for in CRE tech is a growing focus on user experience. This will be the overarching theme for CRE tech trends in 2019 and beyond. As new generations enter the workforce, more tenants will demand a better user experience as new office technologies capable of simplifying their workdays emerge. Building owners need to listen to these desires and provide their tenants with technologies that improve their everyday experiences at the office. Here are just a few ways to do this.

Reprinted courtesy of James Segil, Construction Executive, a publication of Associated Builders and Contractors. All rights reserved.

CGL Insurer’s Duty To Defend Broader Than Duty To Indemnify And Based On Allegations In Underlying Complaint

Businessman dressed in superhero cape

Attorney David Adelstein analyzes the case Southern Owners Ins. Co. v. Gallo Building Services, Inc.

April 10, 2019
David Adelstein - Florida Construction Legal Updates

The duty to defend an insured with respect to a third-party claim is broader than the duty to indemnify the insured for that claim. The duty to defend is triggered by allegations in the underlying complaint. However, an insurer is only required to indemnify its insured for damages covered under the policy. A recent case example demonstrating the duty to defend is broader than the duty to indemnify can be found in Southern Owners Ins. Co. v. Gallo Building Services, Inc., 2018 WL 6619987 (M.D.Fla. 2019).

In this case, a homebuilder built a 270-unit condominium project where the units were included in 51-buildings. Upon turnover of the condominium association to the unit owners, the condominium association served a Florida Statutes Chapter 558 Notice of Construction Defects letter. There was numerous nonconforming work spread out among various subcontractor trades including nonconforming stucco work. The homebuilder incurred significant costs to repair defective work and resulting property damage, and relocated unit owners during repairs. The homebuilder then filed a lawsuit against implicated subcontractors. One of the implicated subcontractors was the stucco subcontractor.

Mr. Adelstein may be contacted at

Latosha Ellis Selected for 2019 Leadership Council on Legal Diversity Pathfinder Program

Gold stars on blue background

LCLD is a growing organization of more than 300 corporate chief legal officers and law firm managing partners.

April 10, 2019
Michael S. Levine - Hunton Andrews Kurth

Hunton Andrews Kurth has selected Latosha Ellis, an associate in the firm’s Insurance Coverage practice, for the 2019 Leadership Council on Legal Diversity (LCLD) Pathfinder Program. Pathfinder is a national yearlong program that trains diverse, high performing, early-career attorneys in critical career development strategies, including foundational leadership and building professional networks.

Mr. Levine may be contacted at

Fifth Circuit Addresses When A Law Firm Should Reasonably Expect A Future Claim In Analyzing Policy Rescission

April 10, 2019
Brian C. Bassett - TLSS Insurance Law Blog

In Imperium Ins. Co. v. Shelton & Assocs., 2019 WL 1096336 (5th Cir. March 6, 2019), the U.S. Court of Appeals for the Fifth Circuit addressed when a lawyer’s professional liability policy may be rescinded based on material misrepresentations in an application concerning potential claims against the firm.

Shelton & Associates, P.A., (“Shelton”) was issued a professional liability insurance policy from Imperium Insurance Company (“Imperium”), on January 24, 2013. Shelton was designated as the “Named Insured” on the policy and the policy’s coverage period extended from February 1, 2013 until February 1, 2014.

Mr. Bassett may be contacted at

Ontario Court of Appeal Clarifies the Meaning of "Living in the Same Household" for Purposes of Coverage Under a Homeowners Policy

Law books on bookshelf

One word can make the difference between a claim being covered or not.

April 10, 2019
Stella Szantova Giordano - Saxe Doernberger & Vita, P.C.

As all insurance coverage attorneys know, how courts interpret certain words and phrases in insurance policies is significant since one word can make the difference between a claim being covered or not. On January 28, 2019, the Court of Appeal for Ontario, in the Ferro v. Weiner1 decision, clarified the jurisprudence on the meaning of “living in the same household” in the context of homeowners policies.

Background Facts

Ms. Enid Weiner owned a lakeside home which was insured under a homeowners policy through Intact Insurance Company (the “Intact Policy”). The Policy listed only Enid Weiner as the Named Insured, but provided coverage to her relatives “while living in the same household” for liability for unintentional bodily injury arising from an insured’s “personal actions anywhere in the world.” Although the lake house was used as a vacation home when Ms. Weiner’s children were small, it was her primary residence for about ten years before she moved into a nursing home. While she never permanently moved back, her three grown children and their families used the house as a cottage, with Enid occasionally accompanying them.

Ms. Giordano may be contacted at

Approaches in the Absence of a Differing Site Conditions Clause

Construction site

Be as detailed and specific in documenting events and costs related to unforeseen conditions, even if contractual remedies are lacking.

April 10, 2019
Parker A. Lewton - Smith Currie

A contractor who has encountered unforeseen conditions will typically rely on the contract’s differing site conditions clause as a means to recovery. Most construction contracts address those issues directly. In ConsensusDocs Standard Agreement and General Conditions between Owner and Constructor, the starting point is § 3.16.2. But what if the contract does not contain a differing site conditions clause? Or, what if the contract does contain such a clause, but the contractor failed to provide adequate notice or satisfy other conditions or requirements of the contract? When reliance on a differing site conditions clause is impractical, a contractor still may seek recovery in certain instances under one or more of the following legal theories: misrepresentation; fraud; duty to disclose; breach of implied warranty; and mutual mistake.


Misrepresentation occurs when an owner “misleads a contractor by a negligently untrue representation of fact[.]” John Massman Contracting Co. v. United States, 23 Cl. Ct. 24, 31 (1991) (citing Morrison–Knudsen Co. v. United States, 170 Ct. Cl. 712, 718–19, 345 F.2d 535, 539 (1965)). A contractor may be able to recover extra costs incurred, under a theory of misrepresentation, if it can show that (1) the owner made an erroneous representation, (2) the erroneous representation went to a material fact, (3) the contractor honestly and reasonably relied on that representation, and (4) the contractor’s reliance on the erroneous representation was to the contractor’s detriment. See T. Brown Constructors, Inc. v. Pena, 132 F.3d 724, 728–29 (Fed. Cir. 1997). These four requirements can be satisfied, for example, through the use of deposition testimony detailing the owner’s representations and the contractor’s reliance thereon. See, e.g., C & H Commercial Contractors, Inc. v. United States, 35 Fed. Cl. 246, 256–57 (1996).

Mr. Parker may be contacted at

Ahlers Cressman & Sleight at Alliance Northwest

April 10, 2019
Jonathan Schirmer – Ahlers Cressman & Sleight PLLC

Please join Ahlers Cressman & Sleight PLLC at Alliance Northwest March 7th in Puyallup, WA. ACS partners Saki Yamada and Brett Hill will be in attendance so stop by the ACS booth and say hello.

Alliance Northwest is the largest business-to-government conference in the Pacific Northwest. Over thirty government agencies from federal, state and local entities will be in attendance. The event also features a 100+ booth tradeshow, workshops, and one-on-one matchmaking with potential buyers. This is a great opportunity to connect with government buyers and prime contractors with over 1000 attendees expected.

March 7th, 2019
Washington Fairgrounds
Mattress Firm Showplex
110 9th Ave
Puyallup, WA

Mr. Schirmer may be contacted at

Is Equipment Installed as Part of Building Renovations a “Product” or “Construction”?

Question mark on white background

What constitutes an “improvement upon real property” necessitating application of the six-year bar?

April 10, 2019
Joshua Lane - Ahlers Cressman & Sleight PLLC

A statute of repose terminates the right to file a claim after a specified time even if the injury has not yet occurred.[1] The construction statute of repose bars claims arising from construction, design, or engineering of any improvement upon real property that has not accrued within six years after substantial completion.[2] But what constitutes an “improvement upon real property” necessitating application of the six-year bar, and when does the bar NOT apply?

The Washington Court of Appeals recently addressed these questions in Puente v. Resources Conservation Co., Int’l.[3] There, the personal representative of the estate of Javier Puente sued several parties after Mr. Puente, an employee of a manufacturer, suffered fatal boric acid burns in 2012 while performing maintenance on a pump system installed at the manufacturer’s facility in 2002. The estate alleged claims of negligence and liability under the Washington Product Liability Act (WPLA).[4] The trial court granted summary judgment to defendants, concluding that the installed pump system constituted a statutory “improvement upon real property” and the six-year statute of repose applied. The estate appealed.

Mr. Lane may be contacted at

Deference Given To Procuring Public Agency Regarding Material Deviation

Forklift in manufacturing facility

The existing principle of law inclines toward judicial deference in public agency competitive bidding disputes.

April 10, 2019
David Adelstein - Florida Construction Legal Updates

Deference will be given to a procuring public agency in a bid protest, particularly when the issue involves whether a bid is non-responsive and constitutes a material deviation from the solicitation. You do not believe me? Perhaps you will after this holding in Biscayne Marine Partners, LLC v. City of Miami, Florida, 44 Fla.L.Weekly D467a (Fla. 3d DCA 2019):

Consequently, no principle of law is clearly established…as to any obligation of the trial court (and, by analogy, an administrative hearing officer) [in a bid protest] to decide or to defer [whether a bid constitutes a material deviation from the solicitation]. If anything, the existing and clearly established principle of law inclines toward judicial deference in public agency competitive bidding disputes when the agency has exercised it discretion absent illegality, fraud, oppression or misconduct.

I do not know about you, but that last underlined sentence is pretty strong language regarding judicial deference!

In this case, Miami (the procuring public agency) issued a Request for Proposals (RFP) for the redevelopment and lease of waterfront property, for the operation of a marina, boatyard, restaurant, wet slips, and a dry storage facility on the property. Miami issued five addenda to the RFP. There were three bidders.

Mr. Adelstein may be contacted at

Restrictions On Out-Of-State Real Estate Brokers Being Challenged In Nevada

Businessman and woman standing back to back

While efforts to preserve local real estate opportunities for local brokers might seem sound, an international brokerage firm is challenging the foundation of that structure.

April 10, 2019
Aaron D. Lovaas - Newmeyer & Dillion LLP

For years, the Nevada Real Estate Division (“NRED”) and its sub-entity, the Nevada Real Estate Commission (“NREC”), have been tasked with administering the licensing procedures applicable to real estate professionals in Nevada, as well as enforcement of the regulations governing business practices, advertising, commissions, license maintenance, and a host of other dayto-day parameters within which the profession operates. Within the past five years, however, the NREC has tasked itself with the publicly stated goal of “protecting” Nevada real estate licensees and the commissions they earn from out-of-state real estate professionals seeking to do business in the Silver State. While efforts to preserve local real estate opportunities for local brokers might seem sound, an international brokerage firm is challenging the foundation of that structure. If they win, the outcome could have huge implications on the real estate industry in Nevada. Businesses, here’s a breakdown of the existing structure and what the challenge is all about.

The Existing Regulatory Structure

Through amending their own regulations, the NRED and NREC have created a regulatory structure that:

  • Prohibits any non-Nevada licensed real estate broker from representing any seller (Nevada based or non-Nevada based) of any Nevada real estate;
  • Prohibits any non-Nevada licensed real estate broker from representing any Nevada resident in the purchase of Nevada real estate; and
  • Allows non-Nevada licensed real estate brokers to represent non-Nevada purchasers of Nevada real estate only if the out-of-state broker formally affiliates (and therefore shares commissions with) a resident Nevada-licensed broker.

Mr. Lovaas may be contacted at

Ninth Circuit Finds Policy’s Definition of “Policy Period” Fatal to Insurer’s “Related Claims” Argument

Trial judge sitting behind bench illustration

These provisions can have significant implications on the applicable policy and policy limits, retroactive date issues, and whether such claims were first made and reported during a particular policy period.

April 10, 2019
Jason M. Taylor - TLSS Insurance Law Blog

Professional liability policies often include some form of a “related claims” or “related acts” provision stating that if more than one claim results from a single wrongful act, or a series of related wrongful acts, such claims will be treated as a single claim and deemed first made during the policy period in which the earliest claim was made. These provisions can have significant implications on the applicable policy and policy limits, retroactive date issues, and whether such claims were first made and reported during a particular policy period. Recently, the Ninth Circuit issued a stern reminder of how the particular policy language can effect, and in this case thwart, the intended scope of the carrier’s “related claims” provision.

In Attorneys Ins. Mut. Risk Retention Grp., Inc. v. Liberty Surplus Ins. Corp., 2019 WL 643442 (9th Cir. Feb. 15, 2019), the Ninth Circuit construed a “related claims” provision included in two consecutive lawyers professional liability policies. During both the 2009–2010 and 2010–2011 insurance policy periods, attorney J. Wayne Allen (“Allen”) was insured through his employer by Liberty Surplus Insurance Corporation’s (“Liberty”) professional liability insurance. Third parties filed suit against Allen during the 2009–2010 policy period in a probate case, and a second, related civil suit during the 2010–2011 policy period.

Mr. Taylor may be contacted at

Illinois Supreme Court Limits Reach of Implied Warranty Claims Against Contractors

Three judges sitting behind the bench

A home purchaser’s remedy where there is economic loss is now limited to those parties with whom it has a direct contractual relationship.

April 10, 2019
Thomas Cronin - Gordon & Rees Construction Law Blog

In a recent decision, the Illinois Supreme Court held that a purchaser of a newly constructed home could not assert a claim for breach of the implied warranty of habitability against a subcontractor where the subcontractor had no contractual relationship with the purchaser. Sienna Court Condo. Ass’n v. Champion Aluminum Corp., 2018 IL 122022, ¶ 1. The decision overruled Minton v. The Richards Group of Chicago, which held that a purchaser who “has no recourse to the builder-vendor and has sustained loss due to the faulty and latent defect in their new home caused by the subcontractor” could assert a claim of a breach of the warranty of habitability against the subcontractor. 116 Ill. App. 3d 852, 855 (1983).

In Sienna Court Condo. Ass’n, the plaintiff alleged that the condo building had several latent defects which made individual units and common areas unfit for habitation. 2008 IL 122022 at ¶ 3. The Court rejected the plaintiff’s argument that privity should not be a factor in determining whether a claim for a breach of the warranty of habitability can be asserted. Id. at ¶ 19. The Court also rejected the plaintiff’s argument that claims for a breach warranty of habitability should not be governed by contract law but should instead be governed by tort law analogous to application of strict liability. Id.

The Court reasoned that the economic loss rule, as articulated in Moorman Manufacturing Co. v. National Tank Co., 91 Ill. 2d 69, 91 (1982), refuted the plaintiff’s argument that the implied warranty of habitability should be covered by tort law. 2008 IL 122022 at ¶ 20. Under the economic loss rule, a plaintiff “cannot recover for solely economic loss under the tort theories of strict liability, negligence, and innocent misrepresentation.” National Tank Co., 91 Ill. 2d at 91. The Court explained that the rule prevented plaintiffs from turning a contractual claim into a tort claim. 2008 IL 122022 at ¶ 21. The Court further noted that contractual privity is required for a claim of economic loss, and an economic loss claim is not limited to strict liability claims. Id. Because the plaintiff’s claim was solely for an economic loss, it was a contractual claim in nature; therefore, the Court concluded that “the implied warranty of habitability cannot be characterized as a tort.” Id. at ¶ 22.

Mr. Cronin may be contacted at


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