735 ILCS 5/13-214.2
(a) Actions based upon tort, contract or otherwise against any person, partnership or corporation registered pursuant to the Illinois Public Accounting Act, as amended, or any of its employees, partners, members, officers or shareholders, for an act or omission in the performance of professional services shall be commenced within 2 years from the time the person bringing an action knew or should reasonably have known of such act or omission
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(735 ILCS 5/13-214.2)
(from Ch. 110, par. 13-214.2)
Sec. 13-214.2.
(a) Actions based upon tort, contract or otherwise
against any person, partnership or corporation registered pursuant to the
Illinois Public Accounting Act, as amended, or any of its employees,
partners, members, officers or shareholders, for an act or omission in the
performance of professional services shall be commenced within 2 years from
the time the person bringing an action knew or should reasonably have known
of such act or omission.
(b) In no event shall such action be brought more than 5 years after the
date on which occurred the act or omission alleged in such action to have
been the cause of the injury to the person bringing such action against a
public accountant. Provided, however, that in the event that an income tax
assessment is made or criminal prosecution is brought against a person,
that person may bring an action against the public accountant who prepared
the tax return within two years from the date of the assessment or
conclusion of the prosecution.
(c) If a person entitled to bring the action is, at the time the cause
of action accrues, under the age of 18, or under a legal disability,
the period of limitations shall not begin to run until the disability
is removed.
(d) This Section shall apply to all causes of action which accrue on or
after its effective date.
(Source: P.A. 85-655; 86-1329.)
Notes of Decisions
Cited in 34
cases (4 in the last 5 years), 1995–2026 · leading case: Khan v. Seidman, LLP
Khan v. Seidman, LLP (2012)
“2(a) (735 ILCS 5/13-214.2(a) (West 2008)), as well as the statute of repose in section 13-214.”
Khan v. Deutsche Bank AG (2012)
“2 of the Code (735 ILCS 5/13-214.2 (West 2008)). That statute provides in relevant part as follows: “(a) Actions based upon tort, contract or otherwise against any person, partnership or corporation registered pursuant to the Illinois Public Accounting Act, as amended, or any of…”
Federated Industries, Inc. v. Reisin (2010)
“Defendants filed a motion to dismiss plaintiffs' complaint pursuant to section 2-619(a)(5) (735 ILCS 5/2-619(a)(5) (West 2008)), asserting that plaintiffs' complaint was filed beyond the applicable statute of limitations for accounting malpractice actions (735 ILCS 5/13-214.2(a)…”
Bova v. U.S. Bank, N.A. (2006)
“2d 364 (1997), in which the court held that a similarly-worded statute of limitations governing actions against accountants, 735 ILCS 5/13-214.2, applied to a plaintiffs claim of fraud against a public accounting firm.”
Evanston Insurance Co. v. Riseborough (2014)
“3d 414, 424 (1997) (statute of limitations for actions against public accountants (735 ILCS 5/13-214.2(a) (West 1996)) was not limited to professional malpractice actions but applied to claims of fraud and tortious interference by former employee suing accounting firm);…”
Zurich Capital Markets Inc. v. Coglianese (2004)
“Statute of Limitations for State Law Claims Michael Coglianese and the Vorisek Defendants argue that all state claims against them are time-barred under the two year statute of limitations set forth in the Illinois Code of Civil Procedure, 735 ILCS 5/13-214.2(a). Section…”
Terrell v. Childers (1996)
“735 ILCS 5/13-214.2(a). According to the Kreger Defendants, the common law claims accrued in May 1991, when the Terrells hired a certified public accountant, Michael Sharpe, to audit the Terrells’ financial status and evaluate TSI’s management of their financial affairs; at the…”
Maniscalco v. Porte Brown, LLC (2019)
“” 735 ILCS 5/13-214.2(a) (West 2016). The parties agree that section 13-214.”
Evanston Insurance Company v. Riseborough (2014)
“20, 2006) (statute of repose for actions against public accountants (735 ILCS 5/13-214.2(b) (West 2004)) applied to the plaintiffs’ third-party action against the auditor of a failed bank, even though the auditor had not provided accounting services to the plaintiffs); Citgo…”
Cashman v. Coopers & Lybrand (1995)
“See 735 ILCS 5/13-214.2(a) (1993). 16 Even if Meagan Stotler, by her father, did not discover the claims raised in the present Complaint until the Elson/Guthrie action was filed on August 3, 1990, the statute of limitations for common law fraud ran on August 3, 1992, almost…”
Maniscalco v. Porte Brown, LLC (2018)
“" 735 ILCS 5/13-214.2(a) (West 2016). The parties agree that section 13-214.”
Lane v. Deutsche Bank (2016)
“735 ILCS 5/13-214.2(a) (West 2014). ¶ 18 As is apparent, the statutes differ not only in their length, but in their start dates.”
— 735 ILCS 5/13-214.2(a) — 27 cases
Khan v. Seidman, LLP (2012)
“2(a) (735 ILCS 5/13-214.2(a) (West 2008)), as well as the statute of repose in section 13-214.”
Federated Industries, Inc. v. Reisin (2010)
“Defendants filed a motion to dismiss plaintiffs' complaint pursuant to section 2-619(a)(5) (735 ILCS 5/2-619(a)(5) (West 2008)), asserting that plaintiffs' complaint was filed beyond the applicable statute of limitations for accounting malpractice actions (735 ILCS 5/13-214.2(a)…”
Zurich Capital Markets Inc. v. Coglianese (2004)
“Statute of Limitations for State Law Claims Michael Coglianese and the Vorisek Defendants argue that all state claims against them are time-barred under the two year statute of limitations set forth in the Illinois Code of Civil Procedure, 735 ILCS 5/13-214.2(a). Section…”
Cashman v. Coopers & Lybrand (1995)
“See 735 ILCS 5/13-214.2(a) (1993). 16 Even if Meagan Stotler, by her father, did not discover the claims raised in the present Complaint until the Elson/Guthrie action was filed on August 3, 1990, the statute of limitations for common law fraud ran on August 3, 1992, almost…”
Terrell v. Childers (1996)
“735 ILCS 5/13-214.2(a). According to the Kreger Defendants, the common law claims accrued in May 1991, when the Terrells hired a certified public accountant, Michael Sharpe, to audit the Terrells’ financial status and evaluate TSI’s management of their financial affairs; at the…”
— 735 ILCS 5/13-214.2(b) — 10 cases
Khan v. Seidman, LLP (2012)
“2(a) (735 ILCS 5/13-214.2(a) (West 2008)), as well as the statute of repose in section 13-214.”
Evanston Insurance Company v. Riseborough (2014)
“20, 2006) (statute of repose for actions against public accountants (735 ILCS 5/13-214.2(b) (West 2004)) applied to the plaintiffs’ third-party action against the auditor of a failed bank, even though the auditor had not provided accounting services to the plaintiffs); Citgo…”
Evanston Insurance Co. v. Riseborough (2014)
“3d 414, 424 (1997) (statute of limitations for actions against public accountants (735 ILCS 5/13-214.2(a) (West 1996)) was not limited to professional malpractice actions but applied to claims of fraud and tortious interference by former employee suing accounting firm);…”
Maniscalco v. Porte Brown, LLC (2019)
“” 735 ILCS 5/13-214.2(a) (West 2016). The parties agree that section 13-214.”
Maniscalco v. Porte Brown, LLC (2018)
“" 735 ILCS 5/13-214.2(a) (West 2016). The parties agree that section 13-214.”
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