14.17.2 Accrual of Breach-of-Contract Claims.

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14.17.2 Accrual of Breach-of-Contract Claims. The rule on accrual of a breach-of-contract action against an insurance producer differs from the rule in negligence cases. In the context of contractual breach, “[t]he traditional construction of [the] rule has been that the [statute] of limitations begins to run when the act upon which legal action is based took place, even though the plaintiff may be unaware of the facts underlying his or her claim.”241 The court in Premium Cigars held that because Premium Cigars’ alleged damages were “open and obvious,” the traditional breach-of-contract rule, rather than...

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