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Calloway v. City of Reno

Citations: 993 P.2d 1259; 1 Nev. 250; 116 Nev. Adv. Rep. 24; 2000 Nev. LEXIS 24Docket: 25628

Court: Nevada Supreme Court; February 29, 2000; Nevada; State Supreme Court

Narrative Opinion Summary

The case involves a class of 164 homeowners who sued various parties, including the City and several construction companies, for defects in their townhouses, resulting in significant water damage. The primary legal issues encompassed claims of breach of warranty, negligence, strict liability, fraud, and misrepresentation. The Nevada Supreme Court reviewed the case following a petition for rehearing. The court upheld the application of the economic loss doctrine, barring negligence claims against subcontractors and the City, and ruled that the townhouses did not qualify as 'products' for strict liability purposes. The court dismissed claims from sixty-five appellants based on statutes of repose, and determined it lacked jurisdiction over the City's cross-appeal for indemnity. Settlements were reached with some parties, and the appellants appealed the application of the economic loss doctrine and related rulings. The court affirmed the dismissal of the negligence and strict liability claims, emphasizing the distinction between contract and tort law as applied to construction defects, and maintaining that economic losses should be addressed through contractual remedies.

Legal Issues Addressed

Application of Statutes of Repose in Construction Litigation

Application: The court upheld the dismissal of claims from sixty-five appellants due to the statutes of repose, which were applied retroactively by the district court.

Reasoning: Furthermore, the court dismissed claims from sixty-five appellants due to statutes of repose.

Economic Loss Doctrine in Construction Defect Cases

Application: The economic loss doctrine barred the homeowners' negligence claims against the subcontractors and the City, limiting them to contractual remedies for economic losses.

Reasoning: The court upheld the district court's application of the economic loss doctrine, which barred the homeowners’ negligence claims against the subcontractors and the City.

Jurisdiction over Cross-Appeals

Application: The court determined it lacked jurisdiction to hear the City’s cross-appeal related to indemnity and contribution claims against the developer and contractor.

Reasoning: Additionally, the City cross-appealed the dismissal of its claims for indemnity and contribution against the developer and contractor, but the court found it lacked jurisdiction to hear the cross-appeal since the City was not an aggrieved party after prevailing in the lower court.

Strict Products Liability in Construction Defect Cases

Application: The court ruled that the homeowners' strict products liability claims were invalid as townhouses are not considered 'products' under strict liability standards.

Reasoning: Furthermore, the court ruled against appellants' strict liability claims against both the subcontractors and the City, stating that a house does not qualify as a 'product' for strict liability purposes.