Montana Code Annotated

Mont. Code Ann. § 27-2-102 (2026)

When Action Commenced

✓ current as of May 2026
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TITLE 27. CIVIL LIABILITY, REMEDIES, AND LIMITATIONS

CHAPTER 2. STATUTES OF LIMITATIONS

Part 1. General Provisions

When Action Commenced

27-2-102. When action commenced. (1) For the purposes of statutes relating to the time within which an action must be commenced:

(a) a claim or cause of action accrues when all elements of the claim or cause exist or have occurred, the right to maintain an action on the claim or cause is complete, and a court or other agency is authorized to accept jurisdiction of the action;

(b) an action is commenced when the complaint is filed.

(2) Unless otherwise provided by statute, the period of limitation begins when the claim or cause of action accrues. Lack of knowledge of the claim or cause of action, or of its accrual, by the party to whom it has accrued does not postpone the beginning of the period of limitation.

(3) The period of limitation does not begin on any claim or cause of action for an injury to person or property until the facts constituting the claim have been discovered or, in the exercise of due diligence, should have been discovered by the injured party if:

(a) the facts constituting the claim are by their nature concealed or self-concealing; or

(b) before, during, or after the act causing the injury, the defendant has taken action which prevents the injured party from discovering the injury or its cause.

(4) Subsection (3) does not apply to actions involving the limitations contained in 27-2-205.

History: En. Sec. 540, C. Civ. Proc. 1895; re-en. Sec. 6457, Rev. C. 1907; re-en. Sec. 9047, R.C.M. 1921; Cal. C. Civ. Proc. Sec. 350; re-en. Sec. 9047, R.C.M. 1935; R.C.M. 1947, 93-2701; amd. Sec. 13, Ch. 12, L. 1979; amd. Sec. 1, Ch. 441, L. 1987.

Notes of Decisions
Cited in 142 cases (23 in the last 5 years), 1979–2026 · leading case: Schoof v. Nesbit, 2014 MT 6 (Mont. 2014).
Schoof v. Nesbit, 2014 MT 6 (Mont. 2014). · cites it 129× “Regarding Issue 2, however, it is my view that we should be applying statutory tolling, rather than common law tolling. Thus, as detailed below, I specially concur as to this issue.”
Blackburn v. Blue Mountain Women's Clinic, 951 P.2d 1 (Mont. 1997). · cites it 113× “Rather, the statute of limitations for negligence claims, codified at § 27-2-204, MCA, and the tolling provisions contained in § 27-2-102, MCA, apply to each of these claims, as well as to Blackburn's allegations of negligence on the part of Dr.”
Christian v. Atl. Richfield Co., 2015 MT 255 (Mont. 2015). · cites it 58× “Section 27-2-102, MCA; Uhler v. Doak, 268 Mont.”
Orr v. State, 2004 MT 354 (Mont. 2004). · cites it 22× “Section 27-2-102, MCA. 34 ¶74 In Montana, no cause of action, or suit, for negligence accrues until all elements of the claim exist.”
Uhler v. Doak, 885 P.2d 1297 (Mont. 1994). · cites it 50× “Since his cause of action had not accrued, according to § 27-2-102(1), MCA, sooner than June 16, the statute of limitations did not commence to run pursuant to subparagraph (2) earlier than that date.”
Nelson v. Nelson, 2002 MT 151 (Mont. 2002). · cites it 24× “Section 27-2-102(2), MCA. However: [t]he period of limitation does not begin on any claim or cause of action for an injury to person or property until the facts constituting the claim have been discovered or, in the exercise of due diligence, should have been discovered by the…”
Brewington v. Employers Fire Ins., 1999 MT 312 (Mont. 1999). · cites it 40× “Section 27-2-102, MCA provides: (1) For the purposes of statutes relating to the time within which an action must be commenced: (a) a claim or cause of action accrues when all elements of the claim or cause exist or have occurred, the right to maintain an action on the claim or…”
Est. of Gleason v. Cent. United Life Ins., 2015 MT 140 (Mont. 2015). · cites it 21× “24 Section 27-2-102(1)(a), MCA. An action is commenced when the complaint is filed.”
Rucinsky v. Hentchel, 881 P.2d 616 (Mont. 1994). · cites it 42× “Section 27-2-102(1)(a), MCA, states in relevant part that a cause of action accrues when all its elements exist or have occurred, the right to maintain an action is complete, and a court is authorized to accept jurisdiction.”
McCormick v. Brevig, 1999 MT 86 (Mont. 1999). · cites it 26× “In 1987, however, the Montana Legislature amended § 27-2-102, MCA, to address the unique problems presented by self-concealing injuries.”
Kaeding v. WR Grace & Co.-Conn., 1998 MT 160 (Mont. 1998). · cites it 22× “" Section 27-2-102(1)(a), MCA. Generally, lack of knowledge by the claimant of the claim or cause of action, or its accrual, does not postpone the beginning of the period of limitations.”
Johnston v. Centennial Log Homes & Furnishings, Inc., 2013 MT 179 (Mont. 2013). · cites it 16× “They argue that the applicable statutes of limitations should have been tolled under the “discovery rule,” which provides: The period of limitation does not begin on any claim or cause of action for injury to person or property until the facts constituting the claim have been…”
— Mont. Code Ann. § 27-2-102(1) — 9 cases
Blackburn v. Blue Mountain Women's Clinic, 951 P.2d 1 (Mont. 1997). “Rather, the statute of limitations for negligence claims, codified at § 27-2-204, MCA, and the tolling provisions contained in § 27-2-102, MCA, apply to each of these claims, as well as to Blackburn's allegations of negligence on the part of Dr.”
Yarbro, Ltd. v. Missoula Fed. Credit Union, 2002 MT 152 (Mont. 2002).
Uhler v. Doak, 885 P.2d 1297 (Mont. 1994). “Since his cause of action had not accrued, according to § 27-2-102(1), MCA, sooner than June 16, the statute of limitations did not commence to run pursuant to subparagraph (2) earlier than that date.”
Christian v. Atl. Richfield Co., 2015 MT 255 (Mont. 2015). “Section 27-2-102, MCA; Uhler v. Doak, 268 Mont.”
McCormick v. Brevig, 1999 MT 86 (Mont. 1999). “In 1987, however, the Montana Legislature amended § 27-2-102, MCA, to address the unique problems presented by self-concealing injuries.”
— Mont. Code Ann. § 27-2-102(1)(a) — 36 cases
Christian v. Atl. Richfield Co., 2015 MT 255 (Mont. 2015). “Section 27-2-102, MCA; Uhler v. Doak, 268 Mont.”
Est. of Gleason v. Cent. United Life Ins., 2015 MT 140 (Mont. 2015). “24 Section 27-2-102(1)(a), MCA. An action is commenced when the complaint is filed.”
Rucinsky v. Hentchel, 881 P.2d 616 (Mont. 1994). “Section 27-2-102(1)(a), MCA, states in relevant part that a cause of action accrues when all its elements exist or have occurred, the right to maintain an action is complete, and a court is authorized to accept jurisdiction.”
Orr v. State, 2004 MT 354 (Mont. 2004). “Section 27-2-102, MCA. 34 ¶74 In Montana, no cause of action, or suit, for negligence accrues until all elements of the claim exist.”
— Mont. Code Ann. § 27-2-102(1)(b) — 5 cases
Est. of Gleason v. Cent. United Life Ins., 2015 MT 140 (Mont. 2015). “24 Section 27-2-102(1)(a), MCA. An action is commenced when the complaint is filed.”
Webb v. T.D., 912 P.2d 202 (Mont. 1996).
Indep. Med. v. DPHHS, 2018 MT 57 (Mont. 2018).
Est. of Athy v. Edgewood, 2026 MT 3 (Mont. 2026).
— Mont. Code Ann. § 27-2-102(2) — 41 cases
Uhler v. Doak, 885 P.2d 1297 (Mont. 1994). “Since his cause of action had not accrued, according to § 27-2-102(1), MCA, sooner than June 16, the statute of limitations did not commence to run pursuant to subparagraph (2) earlier than that date.”
Brewington v. Employers Fire Ins., 1999 MT 312 (Mont. 1999). “Section 27-2-102, MCA provides: (1) For the purposes of statutes relating to the time within which an action must be commenced: (a) a claim or cause of action accrues when all elements of the claim or cause exist or have occurred, the right to maintain an action on the claim or…”
Christian v. Atl. Richfield Co., 2015 MT 255 (Mont. 2015). “Section 27-2-102, MCA; Uhler v. Doak, 268 Mont.”
Schoof v. Nesbit, 2014 MT 6 (Mont. 2014). “Regarding Issue 2, however, it is my view that we should be applying statutory tolling, rather than common law tolling. Thus, as detailed below, I specially concur as to this issue.”
Blackburn v. Blue Mountain Women's Clinic, 951 P.2d 1 (Mont. 1997). “Rather, the statute of limitations for negligence claims, codified at § 27-2-204, MCA, and the tolling provisions contained in § 27-2-102, MCA, apply to each of these claims, as well as to Blackburn's allegations of negligence on the part of Dr.”
— Mont. Code Ann. § 27-2-102(3) — 41 cases
Schoof v. Nesbit, 2014 MT 6 (Mont. 2014). “Regarding Issue 2, however, it is my view that we should be applying statutory tolling, rather than common law tolling. Thus, as detailed below, I specially concur as to this issue.”
Blackburn v. Blue Mountain Women's Clinic, 951 P.2d 1 (Mont. 1997). “Rather, the statute of limitations for negligence claims, codified at § 27-2-204, MCA, and the tolling provisions contained in § 27-2-102, MCA, apply to each of these claims, as well as to Blackburn's allegations of negligence on the part of Dr.”
Johnston v. Centennial Log Homes & Furnishings, Inc., 2013 MT 179 (Mont. 2013). “They argue that the applicable statutes of limitations should have been tolled under the “discovery rule,” which provides: The period of limitation does not begin on any claim or cause of action for injury to person or property until the facts constituting the claim have been…”
Burley v. Burlington N. & Santa Fe Ry. Co., 2012 MT 28 (Mont. 2012).
Christian v. Atl. Richfield Co., 2015 MT 255 (Mont. 2015). “Section 27-2-102, MCA; Uhler v. Doak, 268 Mont.”
— Mont. Code Ann. § 27-2-102(3)(a) — 15 cases
Blackburn v. Blue Mountain Women's Clinic, 951 P.2d 1 (Mont. 1997). “Rather, the statute of limitations for negligence claims, codified at § 27-2-204, MCA, and the tolling provisions contained in § 27-2-102, MCA, apply to each of these claims, as well as to Blackburn's allegations of negligence on the part of Dr.”
Nelson v. Nelson, 2002 MT 151 (Mont. 2002). “Section 27-2-102(2), MCA. However: [t]he period of limitation does not begin on any claim or cause of action for an injury to person or property until the facts constituting the claim have been discovered or, in the exercise of due diligence, should have been discovered by the…”
McCormick v. Brevig, 1999 MT 86 (Mont. 1999). “In 1987, however, the Montana Legislature amended § 27-2-102, MCA, to address the unique problems presented by self-concealing injuries.”
Schoof v. Nesbit, 2014 MT 6 (Mont. 2014). “Regarding Issue 2, however, it is my view that we should be applying statutory tolling, rather than common law tolling. Thus, as detailed below, I specially concur as to this issue.”
Gomez v. State, 1999 MT 67 (Mont. 1999).
— Mont. Code Ann. § 27-2-102(3)(b) — 10 cases
Blackburn v. Blue Mountain Women's Clinic, 951 P.2d 1 (Mont. 1997). “Rather, the statute of limitations for negligence claims, codified at § 27-2-204, MCA, and the tolling provisions contained in § 27-2-102, MCA, apply to each of these claims, as well as to Blackburn's allegations of negligence on the part of Dr.”
Joyce v. Garnaas, 1999 MT 170 (Mont. 1999).
Draggin' Y Cattle Co. v. Addink, 2013 MT 319 (Mont. 2013).
Hein v. Sott Homes, 2015 MT 196 (Mont. 2015).
HKM Assocs. v. Nw. Pipe Fittings, Inc., 900 P.2d 302 (Mont. 1995).
— Mont. Code Ann. § 27-2-102(3Xb) — 1 case
Hein v. Sott Homes, 2015 MT 196 (Mont. 2015).
— Mont. Code Ann. § 27-2-102(4) — 1 case
Wilson v. Brandt & Flathead Valle, 2017 MT 290 (Mont. 2017).
— Mont. Code Ann. § 27-2-102(a) — 1 case
Jarvar v. Title Cash of Montana, Inc. (In Re Jarvar), 422 B.R. 242 (Bankr. D. Mont. 2009).
— Mont. Code Ann. § 27-2-102(l)(a) — 30 cases
Christian v. Atl. Richfield Co., 2015 MT 255 (Mont. 2015). “Section 27-2-102, MCA; Uhler v. Doak, 268 Mont.”
Rucinsky v. Hentchel, 881 P.2d 616 (Mont. 1994). “Section 27-2-102(1)(a), MCA, states in relevant part that a cause of action accrues when all its elements exist or have occurred, the right to maintain an action is complete, and a court is authorized to accept jurisdiction.”
Carroll v. W. R. Grace & Co., 830 P.2d 1253 (Mont. 1992).
Seltzer v. Morton, 2007 MT 62 (Mont. 2007).
Orr v. State, 2004 MT 354 (Mont. 2004). “Section 27-2-102, MCA. 34 ¶74 In Montana, no cause of action, or suit, for negligence accrues until all elements of the claim exist.”
— Mont. Code Ann. § 27-2-102(l)(b) — 6 cases
Est. of Gleason v. Cent. United Life Ins., 2015 MT 140 (Mont. 2015). “24 Section 27-2-102(1)(a), MCA. An action is commenced when the complaint is filed.”
Webb v. T.D., 912 P.2d 202 (Mont. 1996).
Gulf Ins. Co. v. Clark, 2001 MT 45 (Mont. 2001).
Pederson v. Rocky Mountain Bank, 2012 MT 48 (Mont. 2012).
— Mont. Code Ann. § 27-2-102(lXa) — 2 cases
Est. of Gleason v. Cent. United Life Ins., 2015 MT 140 (Mont. 2015). “24 Section 27-2-102(1)(a), MCA. An action is commenced when the complaint is filed.”
Christian v. Atl. Richfield Co., 2015 MT 255 (Mont. 2015). “Section 27-2-102, MCA; Uhler v. Doak, 268 Mont.”
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