California, United States of America
The following excerpt is from Lovell v. Fong, A139309 (Cal. App. 2014):
Further, common law strict liability claims are limited to plaintiffs who have suffered actual damages. In Aas v. Superior Court (2000) 24 Cal.4th 627, 632 (Aas), the court held that homeowners could not recover damages for construction defects in tort actions unless the defects had already resulted in property damage.
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