Vilcinskas v. Sears, Roebuck & Co
In Vilcinskas v. Sears, Roebuck & Co., 144 Conn. 170, 174, 127 A.2d 814 (1956), the Court addressed the constitutionality of General Statutes (1949 Rev.) 8324, the predecessor to 52-584.
In dicta, the court observed that "there is no reason, constitutional or otherwise, which prevents the legislature from enacting a statute, such as 8324, which starts the limitation on actions for negligence running from the date of the act or omission complained of, even though at that date no person has sustained damage and therefore no cause of action has come into existence.
Indeed, such a provision accords with the purposes of statutes of limitation. . . . It is consonant with the purpose of protecting defendants against stale claims that the legislature should enact a statute, such as 8324, which may on occasion bar an action even before the cause of action accrues." Id., 144 Conn. at 174-75.