On January 8, 2026, Holcomb Law Group attorney Jonathan Masters argued Tri-State Insurance Company of Minnesota a/s/o Campus Chalet, Inc. v. East Tennessee Sprinkler Company, Inc. before the Tennessee Supreme Court.
This case is about time—and whether Tennessee’s construction statute of repose bars claims when a contractor’s work is decades old, but the contractor also allegedly performed ongoing inspection and maintenance work years later.
Watch the oral argument
You can watch the Tennessee Supreme Court oral argument here:
Note: The Tennessee Courts YouTube description indicates the argument began later than scheduled due to unforeseen circumstances.
East Tennessee Sprinkler Company (“ETS”) installed a fire-suppression sprinkler system at Campus Chalet in 1992. Years later, a water line burst and caused property damage. Tri-State, Campus Chalet’s insurer, paid the loss and filed a subrogation lawsuit—meaning it stepped into the insured’s shoes and pursued the claim against ETS.
ETS sought dismissal at the outset, arguing the claims were barred by Tennessee’s statute of repose for construction-related claims. Tri-State responded that the suit was not just about the 1992 installation—it was also about ETS’s alleged post-installation inspections, testing, maintenance, and repair obligations that continued over time.
Campus Chalet (a property in Johnson City) had a “dry” fire-suppression sprinkler system installed in 1992 by East Tennessee Sprinkler Company (“ETS”). The relationship didn’t end there. The complaint alleges ETS stayed on the hook—by contract—for ongoing inspection, testing, and maintenance over the years.
In 2020, a water line burst and caused major property damage.
Tri-State (Campus Chalet’s insurer) paid the loss and then filed a subrogation suit in 2023—meaning Tri-State stepped into Campus Chalet’s shoes and sued ETS for negligence and breach of contract.
ETS moved to dismiss. Their pitch was simple: This all “arises out of” a construction project completed in 1992, so the four-year statute of repose bars it.
What the Tennessee Supreme Court is being asked to decide
The Supreme Court granted review to address (1) pleading requirements for allegations like Tri-State’s and (2) the proper interpretation of the four-year statute-of-repose framework in this setting.
In other words: How specific must a complaint be to separate “old construction defect” claims from “newer inspection/maintenance” claims—and when does the repose clock control anyway?
Why this matters
This isn’t just a construction-law puzzle. It hits real-world risk allocation:
- Contractors and service companies: If you keep inspecting and servicing a system, does that create fresh exposure even when the original project is ancient?
- Property owners and insurers: If damage happens years later, can you sue based on the service relationship—without getting tossed out at the pleadings stage?
- Trial courts: Where is the line between a Rule 12 dismissal and a case that needs discovery to sort out “installation vs. maintenance”?
