On February 28th, the First Circuit addressed when a pension fund's professional malpractice action against its auditor and actuary accrued. The Court held that without pleading facts showing a fiduciary or special relationship, the fund cannot invoke the discovery rule to delay the running of the state statute of limitations. The complaint describes arms-length, contractual arrangements for routine financial services. The claims therefore accrued at the time of injury and not when the injury was discovered. Erlich v. Ouellette, Labonte, Roberge and Allen, P.A.