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Minnesota Court Clarifies Post - Fire Restoration Work is Not Necessarily an Improvement | Stinson LLP

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On April 13, 2026, the Minnesota Court of Appeals issued a precedential decision in Haire-Cochran v. 24 Restore, Inc., reversing a district court's dismissal of claims against a restoration company and clarifying an important question regarding the scope of the two-year statute of limitations under Minnesota Statutes section 541.051, subdivision 1(a). The court of appeals held that construction work performed on real property after a fire is not necessarily "an improvement to real property" for purposes of that statute if the intent of the construction is to return the property to its pre-damaged condition. And the shorter two-year limitations period therefore does not automatically apply to claims arising from post-casualty restoration projects.

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Appeal April 16, 2026

Minnesota Court Clarifies Post - Fire Restoration Work is Not Necessarily an Improvement | Stinson LLP

On April 13, 2026, the Minnesota Court of Appeals issued a precedential decision in Haire-Cochran v. 24 Restore, Inc., reversing a district court's dismissal of claims against a restoration company and clarifying an important question regarding the scope of the two-year statute of limitations under Minnesota Statutes section 541.051, subdivision 1(a). The court of appeals held that construction work performed on real property after a fire is not necessarily "an improvement to real property" for purposes of that statute if the intent of the construction is to return the property to its pre-damaged condition. And the shorter two-year limitations period therefore does not automatically apply to claims arising from post-casualty restoration projects.

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