United States · California Code of Civil Procedure
How is California latent construction repose determined?
CCP 337.15 ordinarily sets a ten-year latent construction boundary from substantial completion, no later than its earliest listed completion event.
- Period
- The preset cannot compare trade-specific completion and the listed earliest events, earlier limitations or the statutory exceptions. No computed or paid final repose date is published.
- Trigger
- Substantial completion for the relevant profession or trade and the listed outside commencement events
- Rule
- CCP 337.15
Official current section reviewed. (Amended by Stats. 1981, Ch. 88, Sec. 1.)
Source guide · No automated date
How is California latent construction repose determined?
The preset cannot compare trade-specific completion and the listed earliest events, earlier limitations or the statutory exceptions. No computed or paid final repose date is published.
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Which event starts this CCP 337.15 inquiry?
Substantial completion for the relevant profession or trade and the listed outside commencement events
Subsection (g) uses the earliest applicable final inspection, valid recorded notice of completion, use or occupation, or one year after work termination or cessation.
Responsible actor. The claimant pursuing the identified latent construction or property-injury action. Identify the qualifying participant, trade-specific substantial completion, earliest listed completion event, earlier limitations, exceptions and historical tolling. Only the disclosed component is supported. Additional actual closures, altered orders and excluded service methods require separate review.
CCP 337.15Which comparisons must be resolved before counting?
- Substantial completion for the relevant profession or trade and the listed outside commencement events
- Subsection (g) uses the earliest applicable final inspection, valid recorded notice of completion, use or occupation, or one year after work termination or cessation.
- Resolve the procedural comparisons described here before selecting an applicable clock. This page supplies no computed or paid date.
- Resolve the legally controlling commencement event and competing limitations before bringing the action. Preserve completion, inspection, recording and occupancy evidence.
CCP 12 excludes the triggering day for ordinary day periods. CCP 12a supplies the final judicial-holiday adjustment, including Saturdays and the CCP 135 holidays. CCP 12b addresses qualifying whole-day office closures. Court-day periods exclude intermediate Saturdays, Sundays and judicial holidays. Calendar-day periods include intermediate closed days. Rule 1.11 supplies Friday observance of a Saturday judicial holiday and Monday observance of a Sunday judicial holiday. The calendar includes Lincoln Day, March 31, Juneteenth, Native American Day and Thanksgiving Friday. It excludes Columbus Day and Good Friday as ordinary full judicial holidays. The observed New Year holiday on December 31, 2027 is confirmed in the county schedule. Actual additional closures require separate evidence.
These base components do not add mail, electronic, fax, express or overnight service time. CCP 1013 and 1010.6 identify eligible additions, service conditions and express exceptions. CCP 1005 supplies its own motion-delivery provisions and excludes CCP 1013 for its identified notices. New-trial and CCP 663a intention-notice filings do not receive the stated mail or electronic additions. Establish the actual service method and governing procedure before applying any addition. A summons-service completion event is not determined by the general document-service addition.
The official sections were reviewed, including the retained 2026 and operative-2027 CCP 473 and 415.20 editions. Publication coverage for day and court-day components begins January 1, 2026, or a later expressly stated section effective date. Year components begin no earlier than January 1, 2021, or the section’s later stated effective date, and assume the current reviewed branch applies. These are software coverage boundaries, not findings that an actual act is late. Displayed final dates are confined to the independently reviewed 2026 and 2027 judicial calendar. Closed backward base boundaries and closed minimum-deposition boundaries receive no computed or paid date because their exact adjustment is not implemented. Earlier editions, emergency measures, tolling, different service methods and actual additional closures require separate review.
CCP 12, exclusion of the first dayWhat distinguishes the statutory branches?
Assume a valid recorded completion notice predates the asserted substantial-completion date for one trade. The listed-event cap prevents relying on a later general completion date without review.
The preset cannot compare trade-specific completion and the listed earliest events, earlier limitations or the statutory exceptions. No computed or paid final repose date is published.
Which qualifications change this procedure?
- Earlier limitation remains
- Subsection (d) says the construction period does not extend another limitation. A ten-year component alone is not a final claim deadline.
- Excluded conduct and possessor
- The section excludes willful misconduct or fraudulent concealment and bars its defense by the identified actual possessor or controller.
- Multiple completion events
- Subsection (g) ties substantial completion to each profession or trade and imposes the stated earliest-event cap.
- Service methods and distinct statutory additions
- These base components do not add mail, electronic, fax, express or overnight service time. CCP 1013 and 1010.6 identify eligible additions, service conditions and express exceptions. CCP 1005 supplies its own motion-delivery provisions and excludes CCP 1013 for its identified notices. New-trial and CCP 663a intention-notice filings do not receive the stated mail or electronic additions. Establish the actual service method and governing procedure before applying any addition. A summons-service completion event is not determined by the general document-service addition.
- Edition and calendar coverage
- The official sections were reviewed, including the retained 2026 and operative-2027 CCP 473 and 415.20 editions. Publication coverage for day and court-day components begins January 1, 2026, or a later expressly stated section effective date. Year components begin no earlier than January 1, 2021, or the section’s later stated effective date, and assume the current reviewed branch applies. These are software coverage boundaries, not findings that an actual act is late. Displayed final dates are confined to the independently reviewed 2026 and 2027 judicial calendar. Closed backward base boundaries and closed minimum-deposition boundaries receive no computed or paid date because their exact adjustment is not implemented. Earlier editions, emergency measures, tolling, different service methods and actual additional closures require separate review.
- Identify the qualifying participant, trade-specific substantial completion, earliest listed completion event, earlier limitations, exceptions and historical tolling. Only the disclosed component is supported. Additional actual closures, altered orders and excluded service methods require separate review.
- The preset cannot compare trade-specific completion and the listed earliest events, earlier limitations or the statutory exceptions. No computed or paid final repose date is published.
Which acts and evidence must be preserved?
Questions about CCP 337.15
How is California latent construction repose determined?
Does a single general building completion date always govern?
No. Subsection (g) relates completion to each profession or trade and limits commencement by the earliest listed event.
CCP 337.15(g)Does the ten-year rule cover personal injury as its property-damage branch?
Subsection (a) identifies latent deficiencies and resulting real- or personal-property injury. Classify the claim rather than importing the patent provision’s personal-injury wording.
CCP 337.15(a)Can it extend a shorter limitation for the same action?
No. Subsection (d) expressly says it does not extend the other limitation.
CCP 337.15(d)Official California sources and edition review
Provisions used (15)
| Provision | Purpose |
|---|---|
| CCP 337.15 | The particular actor, event, period and required act |
| CCP 337.15(d) | The separately identified counting, filing, holiday or procedural qualification |
| CCP 337.15(e)-(f) | The separately identified counting, filing, holiday or procedural qualification |
| CCP 337.15(g) | The separately identified counting, filing, holiday or procedural qualification |
| CCP 337.15(a) | The separately identified counting, filing, holiday or procedural qualification |
| CCP 12, exclusion of the first day | The separately identified counting, filing, holiday or procedural qualification |
| CCP 12a, final judicial holidays | The separately identified counting, filing, holiday or procedural qualification |
| CCP 12b, actual whole-day office closures | The separately identified counting, filing, holiday or procedural qualification |
| CCP 12c, backward hearing and service additions | The separately identified counting, filing, holiday or procedural qualification |
| CCP 135, judicial holidays and exclusions | The separately identified counting, filing, holiday or procedural qualification |
| California judicial holiday schedule | The separately identified counting, filing, holiday or procedural qualification |
| Cal. Rules of Court, rule 1.11 | The separately identified counting, filing, holiday or procedural qualification |
| Superior Court of San Bernardino holiday schedule | The separately identified counting, filing, holiday or procedural qualification |
| CCP 1013, service additions and exceptions | The separately identified counting, filing, holiday or procedural qualification |
| CCP 1010.6, electronic service and filing | The separately identified counting, filing, holiday or procedural qualification |