Ron D. Beal, P.A. v. Hartford Fire Insurance Company, 20-14854

In 2006 Beal (assigned the subcontractor’s claim) represented a subcontractor in a dispute with a contractor bonded by Hartford; the parties executed a settlement governed by Kansas law in which Hartford agreed not to contest entitlement to attorney’s fees but reserved the right to challenge the amount.
A three-day evidentiary hearing occurred in Kansas state court in November 2011; on December 2, 2011 Hartford filed proposed findings urging the court to award Hartford $0 in attorney’s fees.
On April 3/4, 2014 the Kansas state court ordered the contractor to pay fees but ruled Hartford did not owe attorney’s fees; the subcontractor’s appeal was affirmed.
The subcontractor later filed bankruptcy and assigned its claim to Beal (assignment effected December 2017). Beal sued Hartford for breach of the settlement agreement on April 3, 2020, alleging breach occurred on December 2, 2011.
The district court dismissed Beal’s breach claim as time-barred (Georgia’s six-year statute of limitations, accrual on December 2, 2011) and rejected Beal’s summary-judgment motion as moot; the Eleventh Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Choice of law for statute of limitations	The contract says Kansas law governs.	Forum procedural law controls; Georgia law applies to statutes of limitations.	Georgia’s statute of limitations governs.
When did the statute of limitations accrue?	Accrual did not occur until April 4, 2014 when the state court ruled against Hartford and Beal suffered actual damage.	Accrual occurred on December 2, 2011 when Hartford submitted proposed findings urging $0 fees (the alleged breach date).	Accrual was December 2, 2011; Beal’s 2020 suit was untimely.
Collateral estoppel (issue preclusion)	Beal argued it could pursue contract claim despite state-court rulings.	Hartford argued the state court necessarily decided Hartford did not violate the settlement agreement.	Court did not need to decide; district court had concluded collateral estoppel barred claim but the appellate opinion affirms on statute-of-limitations grounds.
Prejudgment interest	Even if statute-barred, Beal sought summary judgment awarding prejudgment interest.	No authority supports awarding prejudgment interest for a dismissed/time‑barred claim; no liquidated amount was due from Hartford.	Denied — prejudgment interest not available where no amount was due and claim was dismissed.

Wallace v. Bock, 620 S.E.2d 820 (Ga. 2005) (statute of limitations for contract claims accrues at time of alleged breach)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility pleading standard)
Grupo Televisa, S.A. v. Telemundo Commc’ns Grp., Inc., 485 F.3d 1233 (11th Cir. 2007) (federal courts apply forum conflict‑of‑laws rules)
Berman v. Blount Parrish & Co., Inc., 525 F.3d 1057 (11th Cir. 2008) (de novo review of district court application of statute of limitations)
Owen Lumber Co. v. Chartrand, 157 P.3d 1109 (Kan. 2007) (prejudgment interest generally allowed on liquidated claims)