This recent California Court of Appeals decision held that though the statute of limitations generally begins at the date of completion, developers may have a safe haven by completing construction projects but maintaining possession of properties until the market improves. The court rejected the plaintiff homeowner's argument that because the developer continued to own the home for a 16-month period before sale, the 10-year statute was tolled.
Link to PDF - (EMMA) Ten Year Statute of Repose for Construction Defects