In City School District of Newburgh v. Hugh Stubbins & Associates, Inc., 85 N.Y.2d 535, 650 N.E.2d 399, 626 N.Y.S.2d 741 (1995), which involved a claim for damage to personal property, the court held that in cases against contractors, the accrual date for statute of limitations purposes is completion of performance. Id. at 538.
According to the court, "no matter how a claim is characterized in the complaint--negligence, malpractice, breach of contract, an owner's claim arising out of defective construction accrues on date of completion, since all liability has its genesis in the contractual relationship of the parties." Id.
As the court explicitly noted, however, "in a different category, of course, is injury to the person--a circumstance not present here". Id. at 539.