Which Statute of Limitations?

The Illinois Appellate Court held that a four-year statute of limitations, as opposed to a ten-year statute of limitations for breach of contract actions, applied to a dispute over a construction contract between the water reclamation district and a construction company. The Court noted that under the four-year statute of limitations, the key inquiry is whether the defendant engaged in construction activities enumerated under the statute, 735 ILCS 5/13-214(a), whether or not those activities involved express contractual duties or implied duties. Blinderman Construction Company, Inc. v. Metropolitan Water Reclamation District of Greater Chicago, 325 Ill.App.3d 362, 757 N.E.2d 931 (1st Dist. 2001).