Substantial completion meant action time barred.

- Trial court erred in denying a developer's motion for summary judgment on the homeowners' claim for negligent construction because the developer presented testimony that the sale of the last townhouse closed on December 8, 2004, and that on the date of closing, construction of the townhouses was substantially complete; thus, O.C.G.A. § 9-3-51, the statute of repose, barred any action filed after December 8, 2012, and the homeowners filed the homeowners' suit two months after that date. Ashton Atlanta Residential, LLC v. Ajibola, 331 Ga. App. 231, 770 S.E.2d 311 (2015).

Cited in Turner v. Marable-Pirkle, Inc., 238 Ga. 517, 233 S.E.2d 773 (1977); Benning Constr. Co. v. Lakeshore Plaza Enters., Inc., 240 Ga. 426, 241 S.E.2d 184 (1977); Landon v. Williams Bros. Concrete Co., 149 Ga. App. 699, 256 S.E.2d 99 (1979); Standard Fire Ins. Co. v. Kent & Assocs., 232 Ga. App. 419, 501 S.E.2d 858 (1998); Colormatch Exteriors, Inc. v. Hickey, 275 Ga. 249, 569 S.E.2d 495 (2002); Wilks v. Overall Constr., Inc., 296 Ga. App. 410, 674 S.E.2d 320 (2009).

Am. Jur. 2d.

- 13 Am. Jur. 2d, Building and Construction Contracts, § 115 et seq. 51 Am. Jur. 2d, Limitation of Actions, § 75.

C.J.S.

- 17B C.J.S., Contracts, § 589.

ALR.

- What constitutes "improvement to real property" for purposes of statute of repose or statute of limitations, 122 A.L.R.5th 1.