Christianson v. Conrad-Houston Insurance

Summary

The court affirmed dismissal of Christianson's malpractice action against his insurance broker as barred by the three-year statute of limitations. It held that the insurer's September 2004 letter, together with Christianson's knowledge that he was incurring defense costs and that coverage might be lacking, placed him on inquiry notice and that a reasonable inquiry would have revealed the alleged malpractice. The court also held that equitable tolling was waived and would not apply because Christianson had not previously pursued a claim against the broker.