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DECISIONS DECISIONS TORTS the date of the fraud, not the date of its discovery, bars an auto dealer’s fraud claim against General Motors, the Michigan Supreme Court said on May 28. Boyle v. General Motors Corp., No. 121661. Patricia Boyle sued GM for fraud after the dealership she took over in 1988 went out of business in 1992. She claimed GM misrepresented to her how much capital was required to keep the dealership running. Boyle sued in 1999, four years after she learned about the alleged fraud. The trial court granted the auto maker’s motion for summary judgment on the ground that the six-year statute of limitations for fraud actions ran out in 1998. The court of appeals reversed, ruling that Boyle had six years from her 1995 discovery of the alleged fraud in which to file suit. Reversing, the state Supreme Court stated that earlier case law applied: Boyle’s cause of action accrued when the wrong was done, and she had six years after that in which to file a complaint.

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