Todd Christianson v. Conrad-Houston…

Summary

The Alaska Supreme Court affirmed dismissal of Christianson's professional-negligence claim against his insurance broker as barred by the three-year statute of limitations. It held that the insurer's initial letter, together with Christianson's knowledge of the coverage gaps and his immediate defense expenses, placed him on inquiry notice and that a reasonable inquiry would have revealed the basis of his claim. The court also held that Christianson's equitable-tolling argument was waived and would not apply independently. FABE, Justice, dissenting, would have held that the claim did not accrue until the insurer formally denied coverage and that equitable tolling should have applied during the related litigation.