Ironshore Indemnity Inc. v. Corle Building Systems Inc. v. R&R Ironworks Inc.
Although Connecticut General Statutes §52-584a provides a seven-year statute of limitations against engineers, the statute of limitations can be extended as a result of C.G.S. §52-598a, which permits an action for indemnification to be brought "within three years from the date of the determination of the action against the party which is seeking indemnification by either judgment or settlement." In January 2011, a building owned by USA Hauling and Recycling collapsed. The plaintiff, Ironshore Indemnity Inc., provided insurance coverage to USA Hauling. Ironshore sued Corle Building Systems Inc., alleging it negligently designed the building. Corle filed a third-party complaint against Kenneth Mann, alleging that Mann, a professional engineer, reviewed the drawings and computations, to ensure that the USA Hauling building complied with building codes. Mann moved to dismiss the third-party complaint and argued that C.G.S. §52-584a provides a seven-year statute of limitations against engineers. Corle Building Systems objected that C.G.S. §52-598a provides, "[A]n action for indemnification may be brought within three years from the date of the determination of the action against the party which is seeking indemnification by either judgment or settlement." The District Court found that the seven-year-statute of limitations in C.G.S. §52-584a did not bar Corle Building Systems Inc.'s third-party complaint, and it denied Mann's motion to dismiss.