Essex Insurance Company v. William Kramer & Associates, LLC

Summary

The court held that the evidence did not legally establish that the defendant's continuing course of conduct tolled the three-year statute of repose for the insurer's negligence action. The adjuster's special relationship with the insurer ended when the adjustment was completed and the claim file was closed, and the insurer failed to show either actual knowledge supporting a continuing duty to correct the omission or later wrongful conduct continuing into the limitations period. The court answered the certified question in the negative.