9th Circuit: Crane Company’s Payment Action Barred by Statute of Limitations

Decided in diversity under Alaska’s three-year limitation period for breach of contract, this case provides general guidance on three asserted exceptions to the commencement of the statute of limitations.
A crane company missed the statute by bringing suit three and 1/2 years after terminating service to a hotel project. It raised — and the 9th Circuit rejected — three theories as to why the running of the statute should be deferred so as to make the action timely — an “invoice” theory (the statute doesn’t begin to run until plaintiff submitted it invoice), a “single contract” theory (the statute doesn’t begin to run until plaintiff completed work on a second project also located in the same city) and an “open account” theory (the statute doesn’t begin to run until the account on both projects closed).
Extra bonus: there’s a nice primer on the rules of diversity jurisdiction as applied to LLCs (the defendant/owner operated as an LLC)