What Is the Standard for Determining When a Claim Accrues for Purposes of the Board of Claim's Six-Month Statute of Limitations ?

In Darien Capital Management, Inc. v. Public School Employes' Retirement System, 549 Pa. 1, 700 A.2d 395 (1997), the Pennsylvania Supreme Court adopted a two-prong standard for determining when a claim accrues for purposes of the Board of Claims' six-month statute of limitations. The Court held: A claim accrues when: (1) a claimant is first able to litigate his or her claim, e.g., when the amount due under the claim is known and the claimant is capable of preparing a concise and specific written statement detailing the injury; (2) the claimant is affirmatively notified that he or she will not be paid by the Commonwealth. Id. at 6, 700 A.2d at 397.