Interior Design Services—UCC 2-275 (Four-Year Statute of Limitations)—CPLR 213(2) (Six-Year Statute of Limitations)—”A ‘Mixed’ Transaction, Involving Both Goods and Services,” Requires a Determination Whether the Transaction Is Predominantly for Goods or for Services—Court Applied Six-Year Statute of Limitations—Action Was Timely
This case involved a determination as to whether a contract for interior design services (contract) “is predominantly one for goods or one for services, for statute of limitations [SOL] purposes.” The contract provided for “interior design services, including the procurement of furniture and other items required for achieving the desired design.” The court observed that notwithstanding the extent of interior design services that are provided in New York, to the court’s knowledge “there are no published opinions on this issue in this state.”
