Background
Celeste Puppolo sued former Maryland attorney Jason Shoemaker in December 2023, asserting breach-of-contract and legal-malpractice claims arising from money that Shoemaker allegedly failed to pay her between 2018 and 2019. Shoemaker, who was disbarred in 2020, sent Puppolo a July 2020 letter promising to pay her $23,666.67 and made payments in early 2021.
In May 2021, Puppolo acknowledged those payments but maintained that Shoemaker still owed $7,166.67. The district court granted in part and denied in part each side’s motions, concluding that Maryland’s three-year statute of limitations barred most of Puppolo’s claims but that the undisputed evidence established Shoemaker’s liability for the remaining $7,166.67. Puppolo appealed.
The Court’s Holding
The Fourth Circuit affirmed. Reviewing the summary-judgment ruling de novo, the court held that Puppolo’s claims accrued by 2019 at the latest, when she knew Shoemaker had failed to pay her. The three-year limitations period therefore expired before she filed suit in December 2023.
The court rejected Puppolo’s argument that she only recently discovered an alleged forgery of her signature on a $292,000 check, reasoning that she had received a copy of the check by 2019 and was therefore on inquiry notice. Shoemaker’s later promise to pay $23,666.67 tolled limitations only as to that acknowledged amount, not any larger alleged debt. Because no reasonable juror could find that more than $7,166.67 remained unpaid from the acknowledged debt, the district court properly entered judgment for that amount and treated the remaining claims as time-barred.
Key Takeaways
- Under Maryland’s discovery rule, breach-of-contract and legal-malpractice claims accrue when the plaintiff discovers or should have discovered the facts underlying the claim.
- Possession of facts sufficient to prompt a reasonable investigation constitutes inquiry notice and can begin the limitations period even if the plaintiff has not confirmed every alleged wrongdoing.
- An acknowledgment or promise to pay tolls limitations only to the extent that it clearly and unqualifiedly recognizes a particular debt.
Why It Matters
The decision illustrates that a debtor’s later acknowledgment of a specific amount does not revive broader, already-expired claims. Plaintiffs must investigate known warning signs and file promptly rather than rely on later discovery of additional details to restart the limitations clock.
The unpublished opinion is not binding Fourth Circuit precedent, but it applies settled Maryland accrual, inquiry-notice, and debt-acknowledgment principles to claims against a former attorney.