Client Advisory

The Connecticut Appellate Court was called to clarify Executive Order No. 7G’s impact on the two-year statute of limitations set forth in Conn. Gen. Stat § 52-584 in Marks v. GLT Development Corp., 230 Conn.App. 871. Executive Order No. 7G suspended the statute of limitations effective March 19, 2020 and lifted the suspension on March 1, 2021.

Marks, whose claim arose May 24, 2020 when he was injured by a garage-door malfunction, did not file his complaint until March 24, 2023. The trial court dismissed his complaint on the defendant’s motion due to the expiration of the statute of limitations, interpreting Executive Order No. 7G to suspend the statute of limitations until March 1, 2021, after which point the statute would begin to run again. Plaintiff appealed, arguing that he was entitled to a credit the length of the stay.

The Court affirmed the trial court’s interpretation, explaining that for claims arising between March 19, 2020 and March 1, 2021—when the suspension was in effect—the statute of limitations had begun to run on March 1, 2021 and thus expired on March 1, 2023.