WSHB Colorado Law Update - Construction Defect Subrogation Claim Accrues When the Physical Manifestation of the Defect Appears, Not When Insurer Pays the Claim

In cases governed by Colorado's Construction ("CDARA"), subrogation claims arising from construction defects accrue and the two year statute of limitations for such claims begins to run when the physical manifestation of the defect appears, even though the cause of the defect is not known at that time, and even though the insurer may not have paid the claim until much later. See CRS §13-80-104.

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