How Long Can You Be Sued? The Cutoff Fifteen States Do Not Give You

A statute of repose is the year the door shuts regardless of when a defect turns up. In fifteen jurisdictions it does not shut on a contract claim at all, and in the rest the start date matters more than the number of years.

THE FINDING: in fifteen jurisdictions there is no absolute cutoff on a contract claim

Six have no statute of repose at all	Connecticut, Idaho, Kansas, Maine, New York, Vermont
Nine have one that does NOT bar a contract claim	Delaware, Michigan, Montana, Georgia, District of Columbia, Iowa, Missouri, Oklahoma, Rhode Island
Why that is dangerous rather than academic	The number still exists and gets quoted. Missouri's repose reads as 10 years. It does not close a breach-of-contract claim against a builder. Iowa's 10 years expressly reaches tort, implied warranty and indemnity and NOT breach of contract.
What it means in practice	Where the repose does not bar contract, there is no calendar year at which you are safe. The claim ends when the limitation period runs from the moment it ACCRUED, and accrual can be many years after you left site.
The wrong conclusion to draw	"My state has a ten-year repose, so I am clear at eleven." In those nine states that sentence is false, and reading the number without reading what it bars is how people reach it.

Where it DOES bar a contract claim, the spread is threefold

Shortest, Tennessee	4 years. And Tennessee lets the substantial-completion date be fixed by written agreement, so the start is partly negotiable in the contract you sign
5 years	Arkansas, Louisiana, Virginia
6 years	Colorado, Massachusetts, Mississippi, North Carolina, Utah, Washington
7 years	Alabama, Florida, Kentucky, Wisconsin
8 years	Arizona, New Hampshire, South Carolina
10 years	The largest group, 18 states
Longest, Pennsylvania	12 years from completion of the improvement
Check the year the chart was made	Nevada went from 6 back to 10 in 2019, retroactively. Wisconsin was cut from 10 to 7 in 2018. Ohio cut its written-contract limitation from 8 to 6 in 2021. Charts still circulate with all three of the old figures on them.

The start date matters more than the number of years

Only 18 of the 51 rows run plainly from "substantial completion". The other 33 start somewhere else, and the difference is worth years on the same job.
RUNS FROM YOUR OWN ACT, NOT THE JOB FINISHING: Illinois, Iowa, Nebraska and New Jersey. A groundworker who finished in year one of a four-year build is clear years before the general contractor. That helps a sub and surprises a GC who assumed one shared date.
RUNS FROM THE EARLIEST OF SEVERAL DATES, which starts the clock sooner and helps you: Florida (certificate of occupancy, completion or abandonment), Utah (certificate of substantial completion, certificate of occupancy or first use), Mississippi (written acceptance, occupancy or use), Ohio (first use or first availability for use).
RUNS FROM THE LATEST, which extends your exposure: Nevada (the last of final inspection, notice of completion or certificate of occupancy), New Mexico, and North Carolina, where it is the LATER of substantial completion or your last act, so a small return visit can restart it.
RUNS FROM A DOCUMENT SOMEBODY ELSE FILES: Louisiana, from the recorded acceptance of the work. If acceptance is never recorded within six months of the owner moving in, it runs from occupancy instead.
Keep the completion evidence. A certificate, a signed handover, a dated final inspection. A repose is only a defense if you can prove when it started.

Two clocks, and the repose is usually not the one that kills the claim

The other clock	A limitation period runs from when the claim accrued, often from when the defect was or should have been discovered. A repose runs from completion whether anyone discovered anything or not. You need both numbers.
Where the limitation period is the short one	Colorado is 3 years on a written contract against a 6-year repose. Maryland, North Carolina, Mississippi, South Carolina, New Hampshire and the District of Columbia all sit at 3 years written
Where the repose is the short one	Louisiana: a 5-year repose against a 10-year contract limitation. Tennessee: 4 against 6. In those states the repose is the thing that saves you
Wisconsin does it explicitly	The statute says that where the ordinary limitation is shorter, the shorter one wins, so a contract claim there is normally dead at 6 years and the 7-year repose barely matters
Oral agreements are usually shorter	Arizona 3 against 6 written. Washington 3 against 6. California 2 against 4. Wyoming 8 against 10. If the variation was agreed on the phone, the short clock is the one that applies to it

The exceptions that reopen a closed door

Fraud or concealment, in most states	Arkansas, Illinois, Iowa, Louisiana, Nevada, New Hampshire, North Carolina, Ohio, Tennessee and Wisconsin all disapply or defeat the repose where the defect was fraudulently concealed. Nevada goes furthest: fraud in causing the defect can be sued on at ANY time, with no outer limit
But not everywhere, and this is the inversion	MISSISSIPPI: fraudulent concealment does NOT toll it. NEW JERSEY: concealment, gross negligence and a longer written warranty defeat the repose ONLY where the claimant is a government body. A private homeowner gets none of them
YOUR OWN WARRANTY EXTENDS YOUR OWN EXPOSURE	New Hampshire, Illinois, Ohio, South Dakota and Wisconsin all provide that an express warranty running longer than the repose survives it, for the length of the warranty. Offer a 15-year guarantee in a 10-year state and you have written yourself a 15-year liability
If you still hold the building, it may not protect you	Arkansas, Mississippi, New Jersey, Ohio and Tennessee all deny the defense to a person in actual possession or control of the improvement. Nevada is the opposite: owners and occupiers ARE protected there
Contracting around it	Arkansas and Mississippi forbid it in terms. Tennessee allows the completion DATE to be agreed. Read that clause before you sign
Late discovery often buys extra time	Arizona adds a year for a latent defect found in the 8th. Ohio adds two for one found in the last two of ten. Wisconsin adds three for damage in years 5 to 7. Iowa and Tennessee each add one. These extend the exposure, they do not shorten it

Two states where nobody actually knows

Nevada	No Nevada court has decided whether the 10 years bars a straight breach-of-contract claim
South Dakota	No South Dakota court has decided it either. The better reading is that it does, because the chapter's own findings carve out express warranties, and that carve-out would be pointless if contract claims were not caught
How to treat an unknown	As an unknown. Take advice before relying on it in either direction. An honest gap is safer than a confident answer nobody has tested

Built from a 51-jurisdiction dataset where every row was read whole against the statutes it cites and stamped with the date and the source. It is deliberately built to err LONG: where a repose is tort-only, design-professional-only or residential-excluded, the tool reports no absolute cutoff rather than a false all-clear, because telling a contractor he is off the hook early is the mistake that cannot be undone. Personal injury, wrongful death, product claims against manufacturers, public-work claims (North Carolina drops to 90 days against a local authority) and statutory new-home warranty schemes all run on separate clocks. This is a card for knowing which question to ask, not for deciding whether you have a defense.

Sources: State statutes of repose and limitation, cited state by state in the warranty calculator

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