Pennsylvania Supreme Court Upholds Strict One-year Deadline for Lawsuits Against Home Inspectors
In an October 2025 decision with important implications for real estate errors and omissions liability, the Pennsylvania Supreme Court clarified how claims against home inspectors must be timed under the Pennsylvania Home Inspection Law. In Gidor v. Mangus, the court held that Section 7512 is a statute of repose, not a statute of limitations, meaning any lawsuit seeking damages “arising from a home inspection report” must be filed within one year after the inspector delivers the report.
Unlike statutes of limitations, which may be extended in certain circumstances, a statute of repose creates an absolute deadline. As a result, the one-year period begins when the report is delivered and cannot be paused or extended by the discovery rule or similar equitable doctrines.
Gidor involved a homeowner who purchased a property and later discovered structural issues that were not identified in the inspection. The homeowner filed suit more than one year after receiving the inspection report and asserted statutory claims under the Home Inspection Law, along with related common law and consumer protection theories. The Pennsylvania Supreme Court affirmed dismissal of the claims as untimely, emphasizing that the statute’s language reflects legislative intent to create a firm cutoff date tied to delivery of the report, not later discovery of alleged defects.
For insurers and real estate professionals, this decision provides added predictability and strengthens defenses based on timing, particularly where claims are asserted long after a transaction closes and alleged issues surface months or years later.
Legal Update for Real Estate E&O – February 2026, is prepared by Marshall Dennehey to provide information on recent legal developments of interest to our readers. This publication is not intended to provide legal advice for a specific situation or to create an attorney-client relationship. We would be pleased to provide such legal assistance as you require on these and other subjects when called upon. ATTORNEY ADVERTISING pursuant to New York RPC 7.1 Copyright © 2026 Marshall Dennehey, all rights reserved. No part of this publication may be reprinted without the express written permission of our firm. For reprints or inquiries, or if you wish to be removed from this mailing list, contact MEDeSatnick@mdwcg.com.