On April 26, 2022, Justice Platkin of the Albany County Commercial Division issued a decision in New York State Thruway Auth. v. CHA Consulting, Inc., 2022 NY Slip Op. 50330(U), holding that a claim for professional malpractice against an engineer accrues when the client receives the engineer’s work product, explaining:
A cause of action charging that an engineering professional failed to perform services with due care and in accordance with the recognized and accepted practices of the profession is governed by the three-year Statute of Limitations applicable to negligence actions. The claim accrues upon the client’s receipt of the engineer’s work product.
(Internal quotations and citations omitted).