Negligence – Professional Negligence; Hotel Design; Statute Of Limitations

Where a hotel company sued an architectural firm alleging professional negligence in the design of a hotel, the district court properly found that the claim was barred by the statute of limitations since the adverse domination doctrine did not apply to toll a statute of limitations against third parties, and the appellate court also finds that the Iowa court would not apply the continuous representation rule to toll the statute where the client of an architect in the exercise of reasonable diligence should have discovered its claim before construction was completed. Judgment is affirmed.

12-3919 Cedar Rapids Lodge & Suites, LLC v. JFS Development, Inc., appealed from the Northern District of Iowa, Colloton, J.