D.C. Code § 12-301

Section 12-301 provides a three-year limitations period for the state-law claims at issue.

Youkelsone v. Federal Deposit Insurance ex rel. Washington Mutual Bank · filed 2014-03-28

D.C.Code § 12-301 provides a limitations period of three years for all of Youkel-sone’s state-law claims.

Section 12-301(8) supplies the statute of limitations for non-enumerated causes of action and is not itself a stand-alone cause of action.

Grant v. Spirit Cruises, LLC · filed 2017-10-16(8)

Grant also lists as an independent count the statute of limitations that applies to non-enumerated causes of action, § 12-301(8). ... Needless to say, a statute of limitations does not constitute a stand-alone basis for a cause of action.

D.C. Code § 12-301(8)'s statute of limitations for non-enumerated causes of action is not itself a stand-alone cause of action.

Grant v. Entm't Cruises, Inc. · filed 2017-10-16(8)

Grant also lists as an independent count the statute of limitations that applies to non-enumerated causes of action, § 12-301(8). ... Needless to say, a statute of limitations does not constitute a stand-alone basis for a cause of action.

The court applied § 12-301(8)'s three-year limitations period as tolled during the appellant's first incarceration until his release, but not during his later reincarceration.

Gray v. Staley · filed 2017-11-15(8)

The statute of limitations, which appellant does not dispute is three years, was tolled during appellant’s first period of incarceration from 1979 until no later than December 1992, when appellant was released from prison. See D.C. Code §§ 12-301(8); 12-302(a)(3). However, the limitations period was not tolled again when appellant was arrested and re-incarcerated in June 1994.

D.C. Code § 12-301 provides a three-year limitations period for breach-of-contract claims under subsection (7) and a one-year limitations period for defamation claims under subsection (4).

Samuel v. Wells Fargo & Company · filed 2018-04-27(7), (4)

“The statute of limitations in the District of Columbia for bringing a breach of contract claim is three years,” ... The statute of limitations for defamation in the District of Columbia is one year.

Section 12-301 imposes a three-year limitations period on breach-of-contract claims, generally running from the breach, subject to tolling under the discovery rule and equitable estoppel.

Millennium Square Residential Association v. 2200 M Street LLC · filed 2013-07-10

In the District of Columbia, claims for breach of contract are subject to a three-year statute of limitations. D.C. Code § 12-301. The limitations period begins to run at the time of the defendant's breach. Murray v. Wells Fargo Home Mortg., 953 A.2d 308, 319-20 (D.C. 2008) (citation omitted). The limitations period for a claim for breach of contract may be tolled under the “discovery rule” so that the limitations period does not begin to run until a plaintiff has actual or inquiry notice of its cause of action. Harris v. Ladner, 828 A.2d 203, 205-06 (D.C. 2003). “In addition, where the defendant has done anything . . . to lull the plaintiff into inaction, thereby affirmatively inducing the plaintiff not to file a timely lawsuit, the defendant may be estopped from asserting the bar of the statute of limitations.” Beard v. Edmondson & Gallagher, 790 A.2d 541, 546 (D.C. 2002) (internal citation omitted). Here, MSRA does not allege the statute of limitations as a reason to dismiss the counterclaim. Instead, it argues that it is a reason to limit the damages in the event that the counterclaim is successful. Furthermore, Millennium Defendants raise a factual dispute by alleging that MSRA’s course of conduct lulled them into not timely raising their claims. The factual dispute raised here will not be resolved at this time, and the counterclaim will not be dismissed as barred by the statute of limitations.

Section 12-301(4) gives defamation claims a one-year statute of limitations.

Wiggins v. Philip Morris, Inc. · filed 1994-05-13(4)

Even absent plaintiffs insufficient averments of defamation, plaintiffs defamation claim is also barred by the District of Columbia’s one-year statute of limitations. D.C. Code § 12—301(4). ... Plaintiff alleges that between 1988 and 1990, defendants published the allegedly defamatory remarks. This lawsuit was not filed until February 27, 1992, making these claims fall well beyond the one-year bar prescription.

Section 12-301(4) gives defamation claims a one-year limitations period that begins when the defamatory statement is published, with each discrete statement creating a separate cause of action.

Wallace v. Skadden, Arps, Slate, Meagher & Flom · filed 1998-07-30(4)

In the District of Columbia, the statute of limitations for defamation is one year. See D.C.Code § 12-301(4) (1995). “Defamation occurs on publication, and the statute of limitations runs from the date of publication.” ... The complaint alleges that the defendants made a number of discrete defamatory communications. Each of these statements constituted “a new assault on the plaintiffs reputation,” and each therefore gave rise to a separate right of action.

Section 12-301(4) imposes a one-year statute of limitations on defamation claims.

Stith v. Chadbourne & Parke, LLP. · filed 2001-06-19(4)

Defendant argues that Counts IV, V and VII are all barred by the statute of limitations and cannot be added to the complaint. Statements made by Ms. Norwood were made prior to or at least no later than December 17, 1998, the date of plaintiffs termination, while plaintiffs motion to amend was not filed until April 14, 2000, more than one year later. Because the limitations period for bringing a defamation claim in the District of Columbia is one year, the Court concludes that the statute of limitations has run with respect to Counts IV, V and VII, all relating to statements made by Ms. Norwood.

Section 12-301(4) gives defamation claims a one-year limitation period, and the court treated a conspiracy-to-defame claim as subject to the same period.

Hoffart v. U.S. Government · filed 2001-10-09(4)

The law of the District of Columbia provides a one-year statute of limitation for defamation. D.C.Code § 12-301(4). A claim for conspiracy to defame is subject to the same Umitation period. Thomas v. News World Communications, 681 F.Supp. 55, 72 (D.D.C.1988); Doe v. U.S. Dep’t of Justice, 602 F.Supp. 871, 872-73 (D.D.C.1983). Thus, under the laws of either jurisdiction, the period of Umitation had run by the time that Hoffart brought his claim.

Section 12-301(4) gives a defamation claim a one-year limitations period running from first publication, and later sales or deliveries do not create a new claim.

Jin v. Ministry of State Security · filed 2003-03-24(4)

In the District of Columbia, the statute of limitations for defamation claims is one year from the date of first publication. D.C.Code § 12-301(4); ... District of Columbia courts adhere strictly to the one-year limitation. ... Moreover, the District of Columbia follows the “single publication” rule, whereby publication of defamatory matter “gives rise to but one cause of action for libel, which accrues at the time of the original publication.” ... Because the statute of limitations runs from the date of the original publication, any subsequent sale or delivery of a copy of the publication does not create a new cause of action.

D.C. Code § 12-301’s three-year limitations period for breach-of-contract actions does not bar recovery when the note’s maturity date was orally extended; uncontradicted evidence of the extension may establish the relevant maturity date.

Allen v. Yates · filed 2005-03-03

.Allen also argues that recovery on Note No.l is barred by the District of Columbia’s three-year statute of limitations for actions for breach of contract. D.C.Code § 12-301 (2004). He points out that Yates’ suit was not brought within three years of December 1, 1997, the maturity date under the terms of the Note. In support of his motion for summary judgment, Admiral Yates filed an affidavit in which he stated: "In December of 1997, Mr. Allen and I orally agreed to extend the date of the Note to the time AAI received payment from the government.” Allen did not dispute Admiral Yates’ factual assertion that the maturity date had been extended by oral agreement, but challenged the sufficiency of the affidavit. According to Allen, Yates’ affidavit was inadequate because Yates failed to state affirmatively therein that the affidavit was made on personal knowledge and that the affiant was competent to testify to the matters stated in the affidavit. See Super. Ct. Civ. R. 56(e). Yates’ uncontradicted statement that he personally participated in the conversation described in the affidavit adequately demonstrates his personal knowledge and competence to testify, and Allen’s contrary contention, for which he has cited no authority, is without merit.

Section 12-301(7) imposes a three-year limitation period on breach-of-contract claims, running from accrual of the cause of action.

Pardue v. Center City Consortium Schools of the Archdiocese of Washington, Inc. · filed 2005-06-09(7)

We agree with appellees, however, that the three-year statute of limitations for breach of contract barred this claim. See D.C.Code § 12-301(7) (2001). ... Appellant makes the strained argument that the breach was “recurring” and continued indefinitely while the month’s salary was unpaid — all the way up to her termination in January 2002 (and beyond). She cites no case law for this proposition, and we reject it. Pardue was not, as she asserts, “always behind one [month’s] payment”; rather, she was paid in full for each succeeding month of employment. It is the alleged failure to pay her (double) in July 1998 only that gave rise to her claim and marked the accrual of her cause of action.

Section 12-301(7) gives breach-of-contract claims a three-year limitations period measured from when the right to maintain the action accrues, and equitable tolling does not apply when the plaintiff had the information needed to sue.

Termorio S.A. E.S.P. v. Electrificadora Del Atlantico S.A. E.S.P. · filed 2006-03-17(7)

The court lacks subject matter jurisdiction over plaintiffs’ breach of contract claim both under the Foreign Sovereign Immunities Act and by operation of the applicable statute of limitations. ... The statute of limitations for breach of contract claims is three years from “the time the right to maintain the action accrues.” D.C.Code § 12-301(7) (2006). ... Plaintiffs do not argue that they were prevented from obtaining vital information. Indeed, they filed suit on this same breach of contract claim in Columbia. This fact is fatal to their equitable tolling argument.

Section 12-301(4) gives a defamation plaintiff one year to sue, measured from publication.

Nevius v. Africa Inland Mission International · filed 2007-09-24(4)

The statute of limitations for a defamation claim in the District of Columbia is one year. D.C.Code § 12-301(4). Defamation occurs on publication, and the statute of limitations runs from the date of publication. ... Here, the one-year limitations period ran out on April 7, 2006, well before the complaint was filed on November 17, 2006. Accordingly, Nevius’s defamation claim must be dismissed because it is time barred.

Section 12-301(4) imposes a one-year limitations period on defamation claims, running from publication.

Di Lella v. UNIVERSITY OF DIST. OF COLUMBIA · filed 2008-08-05(4)

The statute of limitations for a defamation claim in the District of Columbia is one year. Wallace v. Skadden, Arps, Slate, Meagher & Flom, 715 A.2d 873, 882 (D.C.1998); see also D.C.Code § 12-301(4). "Defamation occurs on publication and the statute of limitations runs from the date of publication." Wallace, 715 A.2d at 882 (internal citations omitted).

Section 12-301(4) imposes a one-year limitations period for defamation claims, running from publication, subject to equitable tolling when required administrative exhaustion delays suit.

Owens v. District of Columbia · filed 2009-07-06(4)

“In the District of Columbia, the statute of limitations for defamation is one year.” ... “ ‘Defamation occurs on publication, and the statute of limitations runs from the date of publication.’”

Section 12-301(4) sets a one-year limitations period for the listed torts, but claims may proceed past that period when the plaintiff plausibly alleges mental incapacity that tolls the limitations period under § 12-302.

Kennedy v. Berkel & Company Contractors, Inc. · filed 2018-07-24(4)

which is outside the limitations period for many of her tort claims. See D.C. Code § 12-301(4) (setting a one-year limitations period for “libel, slander, assault, battery, mayhem, wounding, malicious prosecution, false arrest or false imprisonment”). ... But assuming the truth of Kennedy’s allegations, the Court cannot conclude as a matter of law that Kennedy was not mentally incapacitated for most of the year between the September 30, 2015 rape and her retention of counsel. ... For now at least, these allegations are sufficient to sustain her claims.

D.C. Code § 12-301(4) sets a one-year limitations period for listed tort claims, while the separate disability provision may toll that period when mental incapacity is adequately alleged.

Kennedy v. Berkel & Co. Contractors, Inc. · filed 2018-07-24(4)

D.C. Code § 12-301 ... setting a one-year limitations period for "libel, slander, assault, battery, mayhem, wounding, malicious prosecution, false arrest or false imprisonment".

Section 12-301(3) imposes a three-year limitations period on property-damage claims, and the period runs once the plaintiff is on inquiry notice of the injury and the defendant’s possible wrongdoing.

Cormier v. District of Columbia Water & Sewer Authority · filed 2008-10-30(3)

We agree with the trial judge’s analysis. Cormier’s theory is that the statute of limitations did not begin to run until Dr. Edwards, “opine[d] on the connection between the pipe problem and WASA’s water (on) May 2, 2003,” more than two months after he filed his lawsuit. This contention is altogether lacking in merit. If we were to accept it, then a plaintiff could defer the running of the statute by simply failing to consult an expert. ... We conclude that on this record, at least as to the two properties in question, Cormier was on inquiry notice more than three years before he brought suit, and no impartial trier of fact could reasonably find to the contrary.

Section 12-301(8) requires an action to be brought within three years after the right to maintain it accrues; the period begins when the plaintiff has actual or inquiry notice of a cause of action, including an injury, its cause, and some evidence of wrongdoing.

Cevenini v. Archbishop of Washington · filed 1998-02-12(8)

The applicable statute of limitations in these eases provides that an action must be brought within three years “from the time the right to maintain the action accrues.” D.C.Code § 12-301(8) (1995). ... Under both the general rule of claim accrual and the discovery rule exception, the statute of limitations begins to run when a plaintiff either has actual knowledge of a cause of action or is charged with knowledge of that cause of action.

D.C. Code § 12-301(8) gives tortious-interference claims a three-year limitations period that begins when the plaintiff knows or reasonably should know of the injury, its cause, and some evidence of wrongdoing; actual notice of the full extent of the wrongdoing is unnecessary.

Capitol Services Management Inc. v. Vesta Corporation · filed 2018-07-25(8)

It is not necessary that CSMI have “actual notice” of the full extent of Vesta’s involvement, as CSMI contends. ... A plaintiff is on “inquiry notice” pursuant to the discovery rule “when ‘the plaintiff has reason to suspect that the defendant did some wrong, even if the full extent of the wrongdoing is not yet known.’”

D.C. Code § 12-301(8) gives tortious-interference claims a three-year limitations period, and accrual occurs when the plaintiff has reason to suspect the injury and some wrongful conduct rather than when every detail is known.

Capitol Servs. Mgmt. v. Vesta Corp. · filed 2018-07-25(8)

It is undisputed that CSMI's claims are subject to a three-year statute of limitations pursuant to ... At issue, then, is when the three-year statute of limitations began to run.

Section 12-301(8) imposes a three-year limitations period that may be tolled until the plaintiff knows of the injury, its cause, and some evidence of wrongdoing, and potentially until the plaintiff realizes the harm’s impact.

Nwachukwu v. Karl · filed 2002-08-26(8)

The defendant correctly notes that the statute of limitations for these claims is three years. ... Based on inquiry notice, the statute of limitations is tolled until the plaintiff is aware of the injury, its cause, and some evidence of wrongdoing. ... Further, the statute of limitations may be tolled until the plaintiff realizes the impact of the harm.

Section 12-301(2) gives three years for claims to recover personal property or damages for its unlawful detention; a conversion claim accrues on demand and refusal when the property was lawfully acquired, but immediately when it was unlawfully acquired.

Malewicz v. City of Amsterdam · filed 2007-06-27(2)

The statute of limitations at issue here is the District of Columbia’s three-year statute for claims relating to “the recovery of personal property or damages for its unlawful detention.” D.C.Code § 12-301(2); ... If a defendant lawfully acquires the property in the first instance (e.g., through a bailment), a claim for conversion accrues when the plaintiff demands the return of the property and the defendant refuses, or when the defendant takes some action that a reasonable person would understand to be either an act of conversion or inconsistent with a bailment. ... But when the defendant did not acquire the property lawfully in the first instance, the claim accrues immediately and there is no need for a demand and refusal to trigger the statute of limitations. See Shea v. Fridley, 123 A.2d 358, 361 (D.C.1956).

Section 12-301(7) applies a three-year limitations period to an unjust-enrichment claim, which accrues no later than the plaintiff's last service when compensation is refused.

News World Communications, Inc. v. Thompsen · filed 2005-07-14(7)

On the strength of the decision in Baer and in the other authorities cited, we conclude that in the present case, the statute of limitations began to run no later than April 4,1995. By that date, Ms. Thompsen had performed her last service to the Times, the Times had declined to compensate her, and, according to Ms. Thompsen, the Times had begun to process the information and ideas that she had provided and had put them to use for the newspaper’s own benefit.

Section 12-301(8) imposes a three-year limitations period on an unjust-enrichment claim, and allegations of tax payments within the three years before amendment were timely enough to proceed.

Flagstar Bank, FSB v. Advanced Financial Investments, LLC · filed 2025-04-10(8)

For pleading purposes, that statement sufficiently alleged that Flagstar continued to pay taxes on the condo within the three-year limitations period immediately preceding the filing of its amended complaint.

Under D.C. Code § 12-301(8), a fraud claim is subject to a three-year statute of limitations.

Suarez v. Compass Coffee LLC · filed 2025-11-03(8)

Unlike his RICO claim, Mr. Suarez’s fraud claim is subject to a slightly shorter three-year statute of limitations. See Lu, 45 F. Supp. 3d at 93 (citing D.C. Code § 12-301(8)).

Section 12-301(8) imposes a three-year limitations period on claims for fraud, negligent misrepresentation, and negligent supervision.

Haralson v. Management & Training Corp. · filed 2010-07-20(8)

Defendant argues that all claims should be dismissed because “[p]laintiff filed suit well beyond three years from the date on which she received her GED.” (Mot. at 3.) The Court agrees with defendant that a three-year statute of limitations applies to plaintiffs claims of fraud, negligent misrepresentation, and negligent supervision. See D.C.Code § 12-301(8); see also, e.g., Drake v. McNair, 993 A.2d 607, 617 (D.C.2010) (applying three-year statute of limitations to fraud and misrepresentation).

Section 12-301(8) imposes a three-year statute of limitations on unjust enrichment claims.

United States ex rel. Washington v. Education Management Corp. · filed 2012-05-11(8)

The unjust enrichment claim is subject to a three-year statute of limitations. D.C.Code § 12-301(8).

D.C. Code § 12-301(8) supplies a three-year limitations period for these claims, but fraudulent concealment can toll that period, so dismissal is premature when timeliness depends on contested facts.

Vox Media, Inc. v. Mansfield · filed 2018-08-20(8)

While a claim generally accrues under District of Columbia law " 'when the plaintiff has knowledge of (or by the exercise of reasonable diligence should have knowledge of) (1) the existence of the injury, (2) its cause in fact, and (3) some evidence of wrongdoing,' " fraudulent concealment "tolls the running of the statute of limitations."

Section 12-301(8) provides a three-year limitations period, but the court could not find the claim conclusively time-barred at the pleading stage.

Vox Media, Inc. v. Mansfield · filed 2018-08-20(8)

Vox does not dispute that its claims are governed by the District of Columbia’s three-year statute of limitations pursuant to D.C. Code § 12-301(8). ... Therefore, the Court cannot conclude, at this stage of the proceedings, that Vox’s complaint is conclusively time-barred.

When a plaintiff sues to enforce a debt acknowledgment that operates as an account stated, the three-year limitations period for general contract actions under § 12-301(7) applies rather than the UCC’s four-year period for sales contracts.

Tiger Steel Engineering, LLC v. Symbion Power, LLC · filed 2018-11-08§ 12-301(7)

Following the analysis in Fisher Sand, we conclude that in suing on the debt acknowledgment letter, Tiger Steel in effect sued on an account stated and, for that reason, its suit was subject to the limitations period governing general contract actions under §12-301 (7). See Fisher Sand & Gravel Co., 837 N.W.2d at 255. Thus, the trial court did not err in determining that the applicable limitations period was three years.

For a breach-of-contract claim in the District of Columbia, § 12-301(7) imposes a three-year statute of limitations, and a single contractual misrepresentation does not restart the limitations period through continuing damages or later invoices.

Fiberlight, LLC v. Washington Metropolitan Area Transit Authority · filed 2018-11-08(7)

The statute of limitations for a breach of contract claim in the District of Columbia is three years. D.C. Code § 12-301(7).

D.C. Code § 12-301(8) imposes a three-year residual limitations period on § 1983 claims, and claims filed after that period are time barred unless they relate back.

Smith v. Dist. of Columbia · filed 2019-05-16(8)

Section 12-301(8) imposes a "three-year residual statute of limitations" on " section 1983 claims."

Section 12-301(7) gives contract actions a three-year limitations period that generally begins when the breach occurs.

Mawakana v. Board of Trustees of the University of the District of Columbia · filed 2019-06-14(7)

A contract action must be brought within three years of the date on which the ‘right to maintain the action accrues.’ An action for breach of contract generally accrues at the time of the breach.

Section 12-301(7) provides a three-year limitations period for contract claims in the District of Columbia.

Service Employees International Union National Industry Pension Fund v. Hebrew Homes Health Network, Inc. · filed 2019-09-12(7)

The District of Columbia has a three-year limitations period for contract claims. D.C. Code § 12-301(7).

A breach-of-contract claim must be filed within three years, and the limitations period generally begins when the breach occurs; on these allegations, the claim accrued when the defendants allegedly terminated the plaintiffs in 2017, so the suit was timely.

Butler v. Augustine · filed 2020-05-06(7)

In the District of Columbia, Plaintiffs must bring a claim for breach of contract within three years of the breach. See D.C. Code § 12-301(7); Eastbanc, 940 A.2d at 1004 (“A cause of action for breach of contract accrues, and the statute of limitations begins to run, at the time of the breach.” (internal quotation omitted)).

D.C. Code § 12-301(7) imposes a three-year statute of limitations on contract claims, and the court applies it to bar claims accruing more than three years before suit.

Moini v. Wrighton · filed 2022-05-13(7)

The statute of limitations for these claims is three years. See D.C. Code § 12-301(7).

D.C. Code § 12-301(8) requires a medical-malpractice action to be filed within three years after the right to maintain the action accrues, absent a valid statutory extension.

Waugh v. Medstar Georgetown University Hospital · filed 2019-03-14(8)

As a result, appellant was required to file his action no more than three years after “the time the right to maintain the action accrue[d],” D.C. Code § 12-301(8), with no extension.

For professional-negligence claims, § 12-301(3)'s three-year limitations period begins when the right to maintain the action accrues.

Wash. Tennis & Educ. Found., Inc. v. Clark Nexsen, Inc. · filed 2018-08-20(3)

The statute of limitations begins to run "from the time the right to maintain the action accrues."

Section 12-301(7) imposes a three-year limitations period for contract claims, and under the discovery rule the claim accrues when the plaintiff knew or should have known of the injury, its cause, and evidence of wrongdoing.

Lucas v. District of Columbia · filed 2019-10-02(7)

The plaintiff’s contract and negligence claims are governed by the District of Columbia’s three-year statute of limitations. D.C. Code §§ 12-301(7); (8). ... where the relationship between the fact of injury and the wrongful conduct is obscure at the time of injury, “D.C. courts apply a more forgiving ‘discovery rule’ under which a claim accrues only if a plaintiff has actual or inquiry notice of a cause of action, regardless of when the injury occurred.”

Section 12-301(8) imposes a three-year limitations period running from when the claim accrues, and the discovery rule can delay accrual until the plaintiff knew or reasonably should have known of the injury, its cause, and evidence of wrongdoing.

Momenian v. Davidson · filed 2020-03-01(8)

The limitations period for Plaintiffs’ claims is three years from the date the claims accrued. D.C. Code § 12-301(8); see Momenian, 878 F.3d at 388.

D.C. Code § 12-301(8) imposes a three-year limitations period running from accrual, and these claims were untimely because no accrual rule tolled the period.

Momenian v. Davidson · filed 2021-03-03(8)

The applicable limitations period for the plaintiffs’ claims is three years from the date the claims accrued. D.C. Code § 12-301(8); see Momenian II, 878 F.3d at 388.

D.C. Code § 12-301(a) gives tort and breach-of-contract claims a three-year limitations period measured from accrual.

Woodland Drive LLC v. Courtovich · filed 2021-09-30(a)

Under District law, the statute of limitations for the tort and breach of contract claims is three years.

Under § 12-301(8), a § 1983 claim has a three-year limitations period that begins when the injury occurs; here, the period began at the plaintiff's termination.

Carter v. District of Columbia · filed 2023-07-07(8)

The limitations period begins to run “at the time the injury actually occurs.” ... Here, “at the absolute latest, the plaintiff’s claim accrued on the date of [his] termination.” ... Thus, as Carter agrees, see Pl.’s Suppl. Mem. at 2, the three-year-clock began running when Carter was fired on June 13, 2019.

Section 12-301(8) imposes a three-year limitations period on these tortious-interference claims; applying the discovery rule, the period began when CSMI had actual or inquiry notice of injury, causation, and evidence of wrongdoing, making its complaint untimely.

Capitol Services Management Inc. v. Vesta Corporation · filed 2023-08-25(8)

Because CSMI filed this action on August 28, 2017, see generally Compl., ECF No. 1; it must not have had notice of these three elements until after August 28, 2014 to survive Vesta’s statute of limitations challenge on this Motion for Summary Judgment, see D.C. Code § 12-301(8).

For a misappropriation claim, § 12-301(8)'s three-year limitations period begins when the plaintiff knew or reasonably should have known of the injury caused by the defendant's wrongdoing, rather than automatically when the image was published.

Toth Gray v. Harco, Inc. · filed 2024-06-17(8)

Here, the applicable statute of limitations is three years. D.C. Code § 12-301(8). This period begins to run “when a plaintiff either has actual knowledge of a cause of action or is for some reason charged with knowledge of that cause of action.”

Section 12-301 requires D.C. breach-of-contract and negligence claims to be filed within three years after accrual, with accrual potentially governed by the discovery rule when the injury or breach is not readily discernible.

Deka USA Dim Property One Lp v. Whiting-Turner Contracting Company · filed 2025-10-22

“In D.C., to maintain a cause of action for breach of contract or negligence, a litigant must bring suit within three years from when a claim ‘accrues.’”

Section 12-301(7) provides a three-year limitations period, and under the discovery rule the period runs from when the plaintiff knew or reasonably should have known of an injury, its cause, and evidence of wrongdoing; whether accrual occurred is generally a factual question.

Fred Ezra Co. v. Psychiatric Institute of Washington, D.C. · filed 1996-12-30(7)

Given our ruling in Diamond, the questíon is whether Ezra filed its claim within three years of the time it knew, or through the exercise of reasonable diligence should have known, of its claim. ... Hence, we cannot say as a matter of law that Ezra had actual notice of its claim within the three year statute of limitations. ... All parties agree that the applicable statute of limitations on these claims is three years. ... See ... D.C.Code § 12-301(7), (8) (1995 Repl.).

For claims governed by subsections (7) and (8), the three-year limitations period runs from when the claimant knew or reasonably should have known of the injury, its cause, and some evidence of wrongdoing; claims filed after that period are time-barred.

Cauderlier & Associates, Inc. v. Zambrana · filed 2007-12-28(7) and (8)

To the extent that Zambrana’s counterclaims are based on the alleged misuse of La Ruche by Cauderlier for the benefit of CAI’s purchase of the Property, the accrual point would have been when Zambrana was made aware, or should have become aware, of such misuse. ... Zambrana, then, either knew or should have known in 2000 of his allegation that La Ruche was being misused by Cauderlier to benefit CAI’s purchase of the Property. Because his Answer was filed on October 24, 2005, any counterclaims based upon this allegation are time-barred by the three-year statute of limitations.

Section 12-301 gives negligence and trespass claims a three-year limitations period that runs from accrual; dismissal on limitations grounds is improper when the complaint does not establish when the claims accrued.

Matiella v. Murdock Street LLC · filed 2023-07-21(3), (8)

Under the law of the District of Columbia, ... for both negligence claims and for claims to recover for “an injury to real or personal property”—which includes trespass claims—a litigant must bring suit within three years from when the claim accrues. ... And because the Court cannot determine when the limitations period on Plaintiff’s claims began to run, it cannot say at this early stage of the proceedings that those claims are “conclusively time barred.”

Section 12-301(1) requires fifteen years of qualifying adverse use for a prescriptive easement, and the period does not run while the dominant and servient estates are owned or occupied by the same person.

Hefazi v. Stiglitz · filed 2004-12-02(1)

“In addition, the appellants cannot demonstrate that their use of the “party wall” windows was for the statutory period of fifteen years, as required by D.C.Code § 12-301(1) (1981). ... Recognizing this fact, it becomes clear that “the time for acquiring by prescription does not run while the dominant and servient estates are in the occupation of the same person.” ... In this case, the Hefazi and Stiglitz properties were owned by the Wiggins until February 20, 1976, and even though the property subsequently was subdivided and sold, it was owned by a single person, Mr. Beach, until 1989. Therefore, the fifteen-year statutory period could not begin to run until the property was sold as subdivided property to separate owners by Mr. Beach on September 25, 1989. ... Accordingly, the appellants cannot show that they acquired an easement by prescription.”

Section 12-301(1) requires an action to recover land or an interest in land to be brought within 15 years; after that period of qualifying adverse possession, the affected property interest may be extinguished.

Smith v. Tippett · filed 1990-02-07(1)

Although the trial judge did not explicitly discuss the elements of adverse possession, we think that there is a substantial basis in the evidence and in the applicable law for his finding that title passed to Ms. Piggot no later than in 1950. According to the stipulated evidence, the intrusion had by that time existed for at least fifteen years. It was continuous, open and notorious. Under District of Columbia law, as well as the majority rule elsewhere, it matters not whether the initial intrusion was intentional or the result of a mistake as to the boundary line. The construction of the wall was an exercise of dominion. The judge could reasonably conclude that, as of 1950, Ms. Tippett’s predecessor in title owned the portion of the easement occupied by the wall by adverse possession.

Section 12-301(1) provides a 15-year limitations period for recovery of land, but the period does not begin merely because the owner dies; possession must have become sufficiently hostile to constitute adverse possession.

Estate of Wells v. Estate of Smith · filed 1990-06-15(1)

Even if we assume that Mrs. Smith possessed the land pursuant to a tenancy at will which expired with the death of the landlord, ... rather than becoming an adverse possessor, Mrs. Smith became, by operation of law, a tenant at sufferance upon Mrs. Wells’s death in the absence of such hostile possession as is required to assert a claim by adverse possession. ... Accordingly, the death of the owner, by itself was not sufficient to start the running of the statute of limitations. ... D.C.Code § 12-301(1) (1989 Repl.) (statute of limitations for recovery of land is 15 years).

Section 12-301(1) supplies a fifteen-year statutory period for establishing a prescriptive easement through adverse use.

Chaconas v. Meyers · filed 1983-08-02(1)

“Effective user to establish a prescriptive easement must be open, notorious, exclusive, continuous and adverse,” ... for the statutory period of fifteen years. See D.C.Code § 12-301(1) (1981); ... .

Section 12-301(1) supplies a fifteen-year limitations period relevant to establishing a prescriptive easement.

Zere v. District of Columbia · filed 2019-06-06(1)

To establish the existence of a prescriptive easement, a claimant must demonstrate that use of another’s land was open, notorious and adverse for a period of at least fifteen years. Martin, 99 A.3d at 711; see also D.C. Code § 12-301(1) (2012 Repl.) (statute of limitations for bringing a claim for the recovery of land is fifteen years).

For a declaratory-judgment claim concerning an easement, the applicable limitations period is fifteen years—the period for recovery of lands—rather than the three-year period for trespass or unjust enrichment.

Board of Trustees, The Grand Lodge of the Independent Order of Odd Fellow of the District of Columbia v. Carmine's DC, L · filed 2020-02-27(1)

But the operative limitations period is that “for the recovery of lands”: fifteen years. D.C. Code § 12-301[(a)](1) (2012 Repl.)

Section 12-301 establishes a 15-year statutory period for acquiring a prescriptive easement in the District of Columbia.

Zlotnick v. Jack I. Bender & Sons, Inc. · filed 1968-05-16

The statutory period of prescription in the District of Columbia is 15 years. D. C.Code § 12-301 (1967). Since the defendant has had title to Lots 812-814 only since 1963, defendant argues that it has acquired this easement by tacking its use to the usage of its predecessors in title. But defendant has not shown use by its titular predecessors. As Umhau v. Bazzuro, 76 U.S.App.D.C. 394, 133 F.2d 356 (1942), makes clear, tacking is impossible without a showing of privity between users. 3 Powell, Real Property, § 413. Defendant has no privity with the employees of the tenants of the Daly or Logan Buildings. Occasional use by some of a tenant’s employees, for personal rather than business purposes, cannot be imputed to the owner for no action for trespass would lie against the owner for the employees’ personal acts. There was no privity of estate between successive tenants in this case and defendant did not purchase a user from the previous owners of Lots 812, 813, 814. Umhau v. Bazzuro, 76 U.S.App.D.C. at 396, 133 F.2d 356. Defendant does not presently possess a prescriptive easement in Alley B.

Section 12-301 requires fifteen years of actual, open and notorious, exclusive, continuous, and hostile possession to establish title by adverse possession.

Sears v. Catholic Archdiocese of Washington · filed 2010-10-07

To establish title by adverse possession, appellants must demonstrate possession of the land that is “actual, open and notorious, exclusive, continuous, and hostile,” throughout a period of fifteen years.

The three-year limitations period for legal malpractice claims is tolled during an appeal when the same lawyers continue representing the client in the same matter.

Seed Co. v. Westerman Ex Rel. Estate of Westerman · filed 2016-08-12(8)

Because the relevant appeal here involved a continued representation by the same lawyers in the same matter, we hold that the continuous-representation rule tolled the statute of limitations during the appeal.

For legal-malpractice claims, § 12-301(8)'s three-year limitations period is tolled under the continuous-representation rule until the attorney's representation concerning the particular matter ends, and that rule can apply when separate proceedings arise from the same event even if they involve different tribunals, laws, defendants, or relief.

Hiligh v. Sands, Jr · filed 2019-06-10(8)

District of Columbia law provides a three-year statute of limitations for legal malpractice claims. See D.C. Code § 12-301(8). It also provides an exception: the continuous-representation rule. That rule ensures that a legal “malpractice cause of action does not accrue until the attorney’s representation concerning the particular matter in issue is terminated.”

The § 12-301 exception for actions brought by the District of Columbia government does not encompass the separate juridical entity of D.C. Water.

B. Frank Joy, L. L.C. v. Dist. of Columbia Sewer and Water Authority · filed 2019-08-01§ 12-301 exception for actions brought by the District of Columbia government

Instead, we conclusively determined that the separate juridical entity of D.C. Water was not part of “the District of Columbia government” under D.C. Code § 12-301. We see no reason to reach a different conclusion here.

D.C. Code § 12-301(4)'s one-year limitations period bars a libel claim when reasonable diligence would have put the plaintiff on inquiry notice of the claim, and later discovery of a closely connected co-defendant does not toll or revive it.

Chandler v. Berlin · filed 2020-01-30(4)

The discovery rule protects a plaintiff from nonobvious or obscured evidence of wrongdoing; it does not to allow him to turn a blind eye when an investigation would otherwise turn up evidence of a co-defendant’s transgressions, even if a separate but related “harm.”

Because § 12-301 does not specify how to compute its limitations period, the court applies the Superior Court rule extending a deadline that falls on a weekend or legal holiday to the next non-weekend, non-holiday day.

Crockett v. Mayor · filed 2020-04-10D.C. Code § 12-301 (subsection not specified in passage)

Because D.C. Code § 12-301 does not “specify a method of computing time,” the Court concludes that the method provided in the Superior Court rules—which is the same as the one provided in the Federal Rules of Civil Procedure, see Fed. R. Civ. P. 6(a)(1)(C)—governs here.

D.C. Code § 12-301(8) gives quantum meruit and unjust enrichment claims a three-year statute of limitations when no other limitations period is specially prescribed.

Friedman v. Government of Abu Dhabi, United Arab Emirates · filed 2020-05-14(8)

The applicable statute of limitations for Friedman’s quantum meruit and unjust enrichment is three years. 9 See Boyd v. Kilpatrick Townsend & Stockton, 164 A.3d 72, 75 (D.C. 2017); see also D.C. Code § 12-301(8) (statute of limitations for actions not otherwise specially prescribed is three years).

D.C. Code § 12-301(8) provides a three-year limitations period for claims, such as promissory estoppel, for which no other limitation period is specially prescribed; applying the discovery rule, the court held the claim was not conclusively time-barred at the pleading stage.

Wiedmaier v. Opentable, Inc. · filed 2020-06-01(8)

If it applies, the D.C. statute of limitations period for a promissory estoppel claim would be three years. See D.C. Code § 12-301(8) (2020) (providing a three-year limitations period for claims “for which a limitation is not otherwise specially prescribed”).

A takings claim seeking damages for injury to real or personal property is governed by § 12-301(3)'s three-year limitations period, while the fifteen-year period in § 12-301(1) does not apply when the plaintiff's title or ownership is not at issue.

Sim Development, LLC v. District of Columbia · filed 2020-07-02(3) and (1)

Subsection 12-301(1)’s fifteen-year statute of limitations does not apply in this case because “there is no cloud on Plaintiff’s title or question as to Plaintiff’s ownership of the property.” ... Instead, Sim Development seeks to recover “damages for an injury to real or personal property,” D.C. Code § 12-301(3), resulting from the District’s having razed the building at an allegedly inflated cost and graded the land with allegedly contaminated soil. ... Subsection 12-301(3) and its three-year limitations period thus governs here.

D.C. Code § 12-301(3) and (8) impose a three-year limitations period, running from accrual, for trespass/property-injury and negligence claims.

Matiella v. Murdock Street LLC · filed 2024-08-28(3), (8)

Under the law of the District of Columbia, for both negligence claims and claims to recover for “an injury to real or personal property”—which includes trespass claims—a litigant must bring suit within three years from when the claim accrues. D.C. Code § 12-301(3), (8)

Section 12-301(10) covers damage to real property caused by petroleum derivatives and requires suit within five years after the injury is discovered or should reasonably have been discovered.

Minkoff v. Clark Transfer, Inc. · filed 1993-12-07(10)

This provision requires such actions to be commenced within “5 years from the date the injury is discovered or with reasonable diligence should have been discovered.” ... Defendants argue that Section 12-301(10) is inapplicable to this case because the D.C.Code nowhere defines gasoline, diesel, or oil as "toxic" substances. Their argument is unsupported. Section 12-301(10) neither attempts to define all toxic substances, nor excludes petroleum derivatives from its ambit. Furthermore, the toxicity of these substances is well-settled.

Section 12-301(10) supplies a five-year limitations period for toxic-substance damage to real property, while subsection (8)'s three-year catch-all applies to injunctive-relief claims lacking a specific period; accrual follows discovery.

Florida Rock Properties, Inc. v. Hess Corporation · filed 2020-08-10(8), (10)

Florida Rock’s common law damages claims are governed by the District of Columbia’s statute of limitations, which provides “for the recovery of damages for an injury to real property from toxic substances . . . [within] 5 years from the date the injury is discovered or with reasonable diligence should have been discovered.” D.C. Code § 12-301(10); ... Florida Rock’s UST Act claim is for injunctive relief, not damages, ... and is therefore subject to the District of Columbia’s three-year catch-all statute of limitations that applies to actions “for which a limitation is not otherwise specifically prescribed,” D.C. Code § 12-301(8).

Section 12-301(8) imposes a three-year limitations period on stand-alone intentional-infliction-of-emotional-distress claims.

Everson v. Congressional Black Caucus Foundation, Inc. · filed 2020-10-16(8)

Stand-alone IIED claims are subject to the three-year limitations period of D.C. Code § 12-301(8).

D.C. Code § 12-301(a)(8) imposes a three-year limitations period on Capitol Services’ tortious-interference claims, and the claims were untimely because the company had inquiry notice before August 28, 2014.

Capitol Services Management Inc. v. Vesta Corporation · filed 2025-02-18(a)(8)

Capitol Services’ claims against Vesta are subject to a three-year statute of limitations — meaning the suit is time barred if Capitol Services was on notice of its claims before August 28, 2014.

A vendor’s lien has the same limitations period as a land-recovery action, so the court applied the 15-year period rather than the three-year period for contractual debt.

Jackson v. Cash · filed 2021-04-01(1)

Accordingly, in the District of Columbia, a vendor’s lien enjoys the same statute of limitations as recovery in land causes of action.

Enforcement of a vendor’s lien is governed by the fifteen-year limitations period for recovery of real estate under § 12-301(1), not the three-year period for contractual debt.

Jackson v. Cash · filed 2021-04-01(1)

the statute of limitations on enforcing a mortgage or a deed of trust on real property is governed by the statute of limitations applicable to possessory actions at common law for the recovery of real estate. ... Necessarily, the principle applies as well to enforcement of a vendor’s lien.

Section 12-301(1) supplies a fifteen-year limitations period for actions to recover land.

Davis v. Stone · filed 1964-12-07(1)

There is no specific statute of limitations on the foreclosure or redemption of a mortgage in the District of Columbia, but the limitation applicable to the recovery of land is applied. See Talbott v. Hill et al., 49 App.D.C. 96, 261 F. 244 (1919); Sis v. Boarman, 11 App.D.C. 116 (1897). Accord, Campbell v. Ohio National Life Ins. Co., 161 Neb. 653, 74 N.W.2d 546, 557 (1956); 1 Jones, op. cit. supra, § 404; 36 Am.Jur., op. cit. supra, § 131. This is fifteen years. D.C.Code § 12-301(1) (1964 Supp.).

Section 12-301(a)(4) gives libel claims a one-year limitations period, but the discovery rule can delay accrual when the injury and tortious conduct are obscure; here, accrual depended on disputed facts about when the plaintiff knew or should have known of the claim against the defendant.

Chandler v. Berlin · filed 2021-05-28(a)(4)

The District of Columbia has a one-year statute of limitations for libel claims, D.C. Code § 12-301(a)(4) ... When “the relationship between the fact of injury and the alleged tortious conduct [is] obscure,” D.C. courts apply the discovery rule to toll the statute of limitations “until plaintiffs know or reasonably should have known that they suffered injury due to the defendants’ wrongdoing.”

Section 12-301(8) imposes a five-year limitations period for recovering damages to real property from toxic substances, running under the discovery rule when the plaintiff discovers or should discover the injury, its cause, and some evidence of wrongdoing.

400 E Street Sw, LLC v. Chevron U.S.A. Inc. · filed 2021-06-30§ 12-301(8)

The parties agree that the District of Columbia’s five-year statute of limitations “for recovery of damages to real property from toxic substances” applies. D.C. Code § 12-301; ... The statute of limitations starts to run when a plaintiff discovers, or by exercise of reasonable diligence should discover, the injury, its cause, and some evidence of wrongdoing.

Section 12-301(10) covers claims for damages from injury to real property caused by toxic substances, with the limitations period running when the injury is discovered or reasonably should have been discovered; it does not define every toxic substance, and allegations involving mold and toxic chemicals may plausibly fall within it.

Short v. Eu · filed 2023-03-29(10)

Short responds that the applicable statute of limitations is instead a five-year limit under D.C. Code § 12-301(10), which covers actions “for the recovery of damages for an injury to real property from toxic substances.” Pl.’s Opp’n at 1. That limitations period begins to run when “the injury is discovered or with reasonable diligence should have been discovered.” D.C. Code. § 12-301(10). ... Section 12-301(10) does not “attempt[] to define all toxic substances,” and the toxicity of these particular substances is not far-fetched.

Section 12-301(4) provides a one-year period for listed torts, while § 12-301(8) provides a three-year residual period for actions not otherwise specially prescribed; the court applied the three-year period to Ajayi’s § 1983 claims and held his state-law claims untimely.

Ajayi v. District of Columbia · filed 2021-08-31D.C. Code § 12-301(4), (8)

Because § 1983 sets no limitations period, the Supreme Court has “determined that the appropriate statute of limitations for a claim brought under section 1983 ‘is that which the State provides for personal-injury torts.’” ... And where, as in the District of Columbia, more than one limitations period exists, courts “should borrow the general or residual statute for personal injury actions.” Id.; see D. C. Code § 12–301(4) (setting one-year period for listed torts); id. § 12–301(8) (setting three-year period for actions “not otherwise specially prescribed”).

Section 12-301(8) supplies the residual three-year limitations period for claims not specifically listed in § 12-301(4), while a claim intertwined with a listed one-year tort is governed by the one-year period.

Parker v. Grand Hyatt Hotel · filed 2000-11-06(4), (8)

Moreover, D.C.Code § 12-301(4) does not specifically mention intentional or negligent infliction of emotional distress. This does not mean, however, that these two claims are automatically governed by the three-year residual statute of limitations. ... Thus, if the claim of intentional infliction of emotional distress is “intertwined” with a tort - enumerated under D.C.Code § 12-301(4) (one-year limitation), such as assault or battery, the one-year limitation also will govern the intentional infliction of emotional distress claim. Otherwise, the three-year D.C.Code § 12-301(8) limitation applies.

Section 12-301(8) imposes a three-year limitations period on civil actions for which no other limitation is specifically prescribed, running from accrual.

Johnson v. LONG BEACH MORTGAGE LOAN TRUST 2001-4 · filed 2006-08-04(8)

In the District of Columbia, a residual statute of limitations bars civil actions after three years from the date the action accrues, provided that a different statute of limitations does not govern. D.C.Code § 12-301(8) (“Except as otherwise specifically provided by law, actions for the following purposes may not be brought after the expiration of the period specified below from the time the right to maintain the action accrues ... (8) for. which a limitation is not otherwise specially prescribed — 3 years”). This statute applies to Plaintiffs claims of negligence, negligent supervision, and violation of the District of Columbia Consumer Protection Act and Consumer Protection Procedures Act, which do not have their own statutes of limitations.

Subsection (4) imposes a one-year limit on listed intentional torts and on residual tort claims sufficiently intertwined with them, while subsection (8)'s three-year period applies to independent claims.

Rynn v. Jaffe · filed 2006-10-20(4), (8)

In the District of Columbia, claims of libel, slander, assault, battery, mayhem, wounding, malicious prosecution, false arrest, and false imprisonment are subject to a one-year statute of limitations. ... Actions “for which a limitation is not otherwise specifically prescribed” are time-barred after three years. ... Residual tort claims, however, are subject to subsection 4’s one-year limitation if they are sufficiently “intertwined” with subsection 4 claims. ... To qualify for subsection 8’s three-year limitation, a claim of intentional infliction of emotional distress (“IIED”) must be “independent” in that it stems from conduct separate from the alleged subsection 4 wrongs. ... Plaintiffs allege no independent basis for their IIED claim, so it merges with the subsection 4 torts and is time-barred. ... Therefore, plaintiffs’ abuse of process claims are time-barred under D.C.Code § 12-301(4).

The court declined to borrow § 12-301(8)'s three-year personal-injury limitations period for Rehabilitation Act claims, holding that the DCHRA's one-year limitations period applies instead.

Cohen v. Washington Metropolitan Area Transit Authority · filed 2021-11-11(8)

Courts in this district faced with this issue have applied either the District of Columbia’s three-year statute of limitations for personal-injury claims, D.C. Code § 12-301(8), or the one-year statute of limitations for discrimination claims under the District of Columbia Human Rights Act (“DCHRA”), D.C. Code § 2-1403.16(a). ... Thus, the Court holds that the DCHRA is the most closely analogous “state cause of action” from which to borrow a statute of limitations for Rehabilitation Act claims.

D.C. Code § 12-301(5), (7), and (8) provide one- or three-year limitations periods for statutory penalties, simple contracts, and claims lacking another specified limitations period, and the applicable District period can bar a federal claim.

Bond v. Texaco, Inc. · filed 1986-10-08(5), (7), and (8)

The federal cause of action under § 210 of ESA most closely resembles those District of Columbia causes of action addressed by D.C.Code Ann. § 12-301(5), (7) and (8) (1981), limiting, respectively, the time within which to sue upon statutory penalties, contracts, and other miscellaneous causes of action for which a limitations period is not otherwise prescribed. ... This Court is thus constrained to apply the most appropriate District of Columbia statute of limitations, even under the most liberal of which this action is time-barred unless national policy dictates to the contrary. ... Because the plaintiff failed to file his complaint until March 1, 1983, nearly four years thereafter, the Court concludes that the complaint is barred by any of the several potentially applicable District of Columbia statutes of limitations.

Section 12-301(7)'s limitations period is procedural under D.C. choice-of-law principles, so the forum state's limitations period governs; here, New Jersey's six-year period applied instead of D.C.'s three-year period.

AMERICAN CENTER FOR CIVIL JUSTICE, INC. v. AMBUSH · filed 2021-12-03(7)

Accordingly, I REVERSE the USBC’s decision to adopt D.C.’s three-year limitations period. New Jersey’s six-year limitations period is appropriate instead.

Section 12-301's limitations period does not automatically govern as the law of the forum; the court may apply another jurisdiction's limitations period when that jurisdiction has a relationship to the controversy warranting an interest analysis.

Cornwell v. CIT Corp. of New York · filed 1974-03-25

However, Fox-Greenwald is not controlling and will not be applied here. It is this Court’s conclusion that in its most recent decision in Nyhus v. Travel Management Corporation, 151 U.S.App. D.C. 269, 466 F.2d 440 (1972), the Court of Appeals discards the law of the forum approach to statute of limitations questions where it can be demonstrated that other jurisdictions have a prevailing interest in the application of their laws to a case which is brought in this Court. ... Thus, the choice-of-laws rule in the District of Columbia shall apply to conflicting statutes of limitations where it is demonstrated that a jurisdiction outside the forum has a relationship to the controversy that warrants an evaluation of the interest of such jurisdiction in the application of its own rule of law. See Mazza v. Mazza, supra.

The court held that the 2018 amendment to § 12-301(11), including its revival provision, does not apply to claims already adjudicated and dismissed as time-barred under the former limitations period.

Perez v. Kipp Dc Supporting Corporation · filed 2022-02-16(11)

In order to avoid the constitutional implications raised by Defendants, the Court determines that the Sexual Abuse Statute of Limitations Amendment Act of 2018 does not apply to claims such as Ms. Perez’s, which were adjudicated and dismissed as time-barred under the previous statue of limitations.

The extended limitations period in § 12-301(11) does not apply to Title IX claims alleging that a university failed to respond properly to sexual-abuse complaints, because those claims arise from the institution’s response rather than from the sexual abuse itself.

Doe v. Howard University · filed 2022-03-28(11)

First, Doe’s claims are not targeted at an act of sexual abuse. Rather, they charge Howard with failing to respond to her complaints in the correct manner. ... The origination of Doe’s claim is not her rape, but the alleged failures of Howard in responding to her complaint; indeed, that is the specific harm a Title IX claim rectifies.

For a Title IX claim, the court applies D.C.'s three-year residual statute of limitations for personal-injury claims.

Smith v. Howard University · filed 2022-05-25(8)

Accordingly, the court will apply the District of Columbia’s three-year residual personal injury limitations period to Plaintiff’s Title IX claim. Therefore, it was timely filed.

Under § 12-301(10), the five-year limitations period for toxic-substance real-property damage begins when the injury is discovered or reasonably should have been discovered, and the injury is the property damage itself rather than a later refusal to reimburse repair costs.

400 E Street SW, LLC v. Chevron U.S.A. Inc. · filed 2022-07-12(10)

The D.C. Code provides that actions “for the recovery of damages for an injury to real property from toxic substances” “may not be brought” after “5 years from the date the injury is discovered or with reasonable diligence should have been discovered.” D.C. Code § 12-301(10).

Section 12-301(11)'s post-2019 sexual-abuse limitations extension applies to claims potentially revived by the amendment only if they were filed within two years after May 3, 2019, so Doe's 2022 suit was time-barred.

Doe v. Duke Ellington Schoolof the Arts Project · filed 2022-08-05(11)

What this means is that a claim that would have been time barred under the pre-2019 version of § 12-301(11) is entitled to the post-2019 version’s statute-of-limitations extension only if it was filed by May 3, 2021. ... The Court is thus constrained to conclude that Doe has no recourse here: all of her claims against all Defendants are time barred.

D.C. Code § 12-301(8)'s residual three-year limitations period applies to Page's FISA and Bivens claims because an unlawful-search claim does not resemble the intentional torts covered by § 12-301(4).

Page v. Comey · filed 2022-09-01(8), (4)

Looking to D.C. law, the residual three-year limitations period, see D.C. Code § 12-301(8), fits best. Page’s claim is for an unlawful search, which is not akin to the intentional torts listed in D.C. Code § 12-301(4).

D.C. Code § 12-301(8)'s three-year residual limitations period applies to Title VI claims brought in the District of Columbia.

Stafford v. George Washington University · filed 2022-12-23(8)

Agreeing with these decisions, we hold that the District’s three-year residual statute of limitations applies to Title VI claims brought in the District of Columbia.

Section 12-301(8) supplies a three-year residual statute of limitations in the District of Columbia for § 1983 personal-injury claims and, by assumption, the plaintiff’s alleged mental-anguish claim.

Evans v. Kasul · filed 2025-03-14(8)

In the District of Columbia, the relevant statute of limitations is the three-year residual statute of limitations under D.C. Code § 12-301(8).

Section 12-301(8) ordinarily gives intentional-infliction-of-emotional-distress claims a three-year limitations period, unless the claim is intertwined with a claim governed by a specific limitations period.

Brown v. Nationwide Mutual Insurance Company · filed 2026-02-26(8)

IIED claims ordinarily fall within D.C.’s three-year residual limitations period. See D.C. Code § 12-301(8). However, “an IIED claim that is intertwined with any of the causes of action for which a period of limitation is specifically provided . . . is subject to the limitation period for the intertwined claim.”

D.C. Code § 12-301(4) provides a one-year limitations period for specified enumerated intentional torts, while the three-year period covers other tort actions.

Brown v. Hill · filed 2023-05-19(4)

In the District, a 1-year statute of limitations governs specified enumerated intentional torts, and a 3-year statute covers all other tort actions.

Section 12-301(a)(4) provides a one-year limitations period for certain intentional torts, while the residual three-year period applies to other tort actions.

Copeland v. Metropolitan Police Department · filed 2026-02-04(a)(4)

The District of Columbia has two statutes of limitations for tort claims: a one-year statute for certain intentional torts, and a three-year residual statute for all other tort actions. Earle v. District of Columbia, 707 F.3d 299, 305 (D.C. Cir. 2012) (citing D.C. Code § 12–301(4), (8)).

Section 12-301(11), as amended, provides a limitations period for civil actions arising from sexual abuse of a victim under 35 that runs until the victim turns 40 or five years after the victim knew or reasonably should have known of the abuse, whichever is later.

Perez v. Kipp DC Supporting Corporation · filed 2023-06-13(11)

This Act applies to all civil actions “arising out of” sexual abuse of a victim under the age of 35.3 ... The new and expanded limitations period extends to “the date the victim attains the age of 40 years, or 5 years from when the victim knew, or reasonably should have known, of any act constituting sexual abuse, whichever is later.”

The 2019 amendment to § 12-301(11) applies to Perez’s civil claims arising from sexual abuse, including claims based on defendants’ facilitation of the abuse.

Perez v. Kipp Dc Supporting Corporation · filed 2024-07-25(11)

Accordingly, the Court holds that the Act applies to Perez’s claims.

When an intentional-infliction-of-emotional-distress claim is inextricably intertwined with assault allegations, the one-year statute of limitations for assault applies under § 12-301(4).

McCrea v. District of Columbia · filed 2023-06-14(4)

Under that standard, the applicable statute of limitations in this case is the one-year period for assault. See D.C. Code § 12-301(4). Plaintiff’s only surviving claim against Chase arises from, and is inextricably intertwined with, the allegations that he participated in her sexual assault.

Section 12-301 ordinarily gives negligent and intentional infliction of emotional distress claims a three-year limitations period under subsection (8), but applies a one-year period under subsection (4) when those claims are intertwined with a tort specifically listed there.

Rogers v. Johnson-Norman · filed 2006-12-20(4) and (8)

Because D.C.Code § 12-301(4) does not specifically mention either negligent or intentional infliction of emotional distress, these two claims are ordinarily subject to the three-year limitations period of D.C.Code § 12-301(8). ... However, if claims of negligent or intentional infliction of emotional distress are “intertwined” with a tort specifically mentioned by D.C.Code § 12-301(4), such claims are subject to a one-year limitations period.

The complaint was not facially time-barred because, for repeated unlawful contract awards, each violation may begin a new limitations period; the court did not decide whether § 12-301(8) or laches ultimately governs.

Allied Telecom Group, LLC v. District of Columbia · filed 2023-07-24(8)

The Court need not decide whether the three-year statute of limitations or the doctrine of laches applies at this point, because neither would conclusively bar Allied’s suit on the face of the complaint. ... For “a series of repeated violations of an identical nature,” “each violation gives rise to a new cause of action” and “begins a new statute of limitations period as to that particular event.”

D.C. Code § 12-301(a)(4) gives a one-year limitations period for battery claims, so Ruhosha’s battery claim filed after January 15, 2022 was untimely.

Ruhosha v. Maine Medical Center · filed 2024-03-28(a)(4)

Mr. Ruhosha sues MedStar for a battery that he claims happened on January 15, 2021, but the statute of limitations for that claim ran on January 15, 2022, well before he filed this suit. See D.C. Code § 12-301(a)(4) (setting statute of limitations for battery at one year).

For defamation published through mass media, the one-year limitations period under § 12-301(4) begins when the statement is published, not when the plaintiff discovers it.

Mullin v. Washington Free Weekly, Inc. · filed 2001-11-08(4)

In defamation cases, on the other hand, at least where mass media are involved, “the fact of ... injury can be readily determined,” and thus any resulting defamation claims will “accrue ... for purposes of the statute of limitations at the time the injury actually occurs,” i.e., publication.

D.C. Code § 12-301(4) requires defamation claims to be brought within one year of publication, and the single-publication rule generally prevents later online access from restarting that period.

Seltzer v. Financial Industry Regulatory Authority · filed 2023-09-05(4)

In the District of Columbia, defamation claims must be brought within one year of the date that the defamatory statements were published. D.C. Code § 12-301(4); ... In the District of Columbia, the single publication rule governs the statute of limitations for defamatory statements.

Section 12-301(8) provides a three-year catch-all limitations period; a judicial foreclosure claim against a purchaser at a condominium foreclosure sale accrued when that sale occurred.

Staab v. Wells Fargo Bank, N.A. · filed 2024-12-12(8)

Wells Fargo filed its complaint for judicial foreclosure in June 2015, less than three years after the condominium foreclosure sale, when its claim against Ms. Staab first accrued.

Section 12-301(a)(8) supplies a three-year catch-all limitations period when no other limitation is specially prescribed, including for the D.C. Arbitration Act, but that catch-all period is not the proper borrowed period for this ICSID enforcement action.

Webuild S.P.A. v. Argentine Republic · filed 2024-11-19(a)(8)

Because the D.C. Arbitration Act itself lacks a statute of limitations, its limitations period is drawn from the catch-all District of Columbia statute of limitations for actions “for which a limitation is not otherwise specially prescribed—[three] years[.]” D.C. Code § 12-301(a)(8).

Section 12-301(8) supplies a three-year catch-all limitations period for § 1983 actions, running from accrual of the claim.

Murray v. District of Columbia · filed 1993-06-25(8)

Under the three-year “catch-all” limitations period applicable to § 1983 actions under D.C.Code § 12-301(8); see Greenfield v. District of Columbia, 623 F.Supp. 47, 48 (D.D.C.1985), plaintiffs claim would appear to be time-barred, because the statute of limitations would have begun to run (at the latest) when plaintiffs appeal of his Massachusetts conviction was denied in October 1983.

Section 12-301(8) supplies a three-year catch-all limitations period for IDEA attorney-fee actions when no more specific District of Columbia limitations period applies.

Akinseye v. District of Columbia · filed 2002-03-19(8)

Having concluded that a limitation period of more than 30 days should be borrowed by the Court, an exhaustive search for the most analogous District of Columbia statute of limitations was undertaken. This search has failed to uncover any limitation period that is any more appropriate to apply to the claims in this case than the 3-year limitation period of D.C.Code § 12-301(8) proffered by plaintiffs. ... Accordingly, that is the limitation period the Court will borrow.

Section 12-301(4) imposes a one-year limitations period for libel and slander claims, while § 12-301(8) supplies a residual three-year period for claims without a specific period, subject to the rule that an intertwined claim receives the prescribed period.

Jovanovic v. US-Algeria Business Council · filed 2008-06-26(4) and (8)

Here, the District of Columbia’s one-year statute of limitations for libel and slander claims applies to Plaintiffs defamation claim. D.C.Code § 12-301(4); Jankovic, 494 F.3d at 1086. ... Under D.C. law, causes of action for which a limitation is not specifically prescribed by statute are covered by a residual three-year limitations period. See D.C.Code § 12-301(8). However, “[w]hen a cause of action with no prescribed statute of limitations is ‘intertwined’ with one having a prescribed limitations period, District of Columbia courts apply the prescribed period.”

(4) sets one-year limitations periods for specified tort claims, while (2) and (8) set three-year periods for personal-property claims and claims lacking another specially prescribed limitation.

Curtis v. Lanier · filed 2008-02-28(4), (2), (8)

DC Code § 12-301(4) provides a one year statute of limitations for claims of slander, malicious prosecution, false arrest or false imprisonment. ... Libel and defamation actions are also subject to a one year statute of limitations under D.C.Code § 12-301(4). ... D.C.Code § 12-301(2) provides a three year statute of limitations for the recovery of personal property or damages for its unlawful detention. ... D.C.Code § 12-301(8) applies a three year statute of limitations to all actions “for which a limitation is not otherwise specially prescribed.”

Subsection (7) gives breach-of-contract claims a three-year limitations period running from the alleged breach, while subsection (8) supplies a three-year residuary limitations period for claims not otherwise covered.

Parker v. National Corp. for Housing Partnerships · filed 1985-08-22(7), (8)

The statute of limitations in this jurisdiction for a breach of contract claim is three years, commencing at the time of the alleged breach. D.C.Code § 12-301(7). ... Beyond the non-existence of this cause of action in this jurisdiction, the claim is time-barred in that it was filed after the District of Columbia’s residuary limitations period of three years. D.C.Code § 12-301(8) (1981). This claim therefore must be dismissed.

Section 12-301(4) gives assault and battery claims a one-year limitations period, while § 12-301(8) supplies a three-year residual period for IIED claims only when they are not intertwined with a claim covered by a specific limitations period.

Alston v. District of Columbia · filed 2025-03-24(4), (8)

The statute of limitations for assault and battery is one year. D.C. Code § 12-301(4). ... No statute specifically limits the time for filing an IIED claim, so a suit alleging only IIED is subject to the District’s three-year residual statute of limitations. Rendall-Speranza v. Nassim, 107 F.3d 913, 920 (D.C. Cir. 1997); see D.C. Code § 12-301(8). ... The D.C. Court of Appeals has held that only those IIED claims “not intertwined with any of the causes of action for which a period of limitation is specifically provided in the other provisions of section 12-301” are governed by Section 12-301(8)’s three-year residual limitations period.

Section 12-301(8) supplies a three-year residual limitations period for intentional-infliction-of-emotional-distress claims only when they are not intertwined with a claim subject to a specific limitations period.

Lively v. Flexible Packaging Ass'n · filed 2001-01-11(8)

Generally, an action for intentional infliction of emotional distress is governed by the residuary three-year limitation of D.C.Code § 12-301(8) only if it is “not intertwined with any of the causes of action for which a period of limitation is specifically provided.” Saunders v. Nemati, 580 A.2d 660, 665 (D.C.1990). To the extent that Mrs. Lively’s emotional distress claim is based on Mr. Braswell’s sexually discriminatory conduct, it is “intertwined with” her hostile work environment claim and thus it assumes the hostile work environment claim’s one-year limitation period.

Section 12-301(8) supplies a three-year residual limitations period for claims without a specifically prescribed period, while § 12-301(4) prescribes a one-year period for false imprisonment; limitations begin when the right to maintain the action accrues.

Sykes v. US ATTORNEY FOR THE DIST. OF COLUMBIA · filed 2011-03-16(8), (4)

D.C.Code § 12-301 (2011) outlines the statutory time limitations for bringing all types of actions within the District of Columbia. While delineating particular limitations for specific actions, it also contains a catch-all provision, that sets a statute of limitations of three years for those causes of action “for which a limitation is not otherwise limited.” D.C.Code § 12-301(8). ... The statute of limitations for false imprisonment and defamation in the District of Columbia is one year. ... Statutes of limitations begin to run “from the time the right to maintain the action accrues.” D.C.Code § 12-301. The District of Columbia applies the “discovery rule” to determine when a tort action accrues, whereby an action accrues when a plaintiff has knowledge of, or through the exercise of reasonable diligence should have knowledge of “(1) the existence of the injury, (2) its cause in fact, and (3) some evidence of wrongdoing.”

The fifteen-year limitations period in § 12-301(a)(1) applies only to possessory adverse-possession or ejectment-type actions seeking recovery of physical possession, not to a quiet-title claim based on invalidating a foreclosure sale.

Tyroshi Investments, LLC v. U.S. Bank, NA, Successor Trustee to LaSalle Bank National Association · filed 2025-09-11(1)

That extended limitations period applies only to adverse possession or ejectment-type claims seeking to recover physical possession of real property from a party wrongfully occupying it.

For the wrongful-discharge and fraud or misrepresentation claims at issue, D.C. Code § 12-301 provides a three-year limitations period.

Said v. Nat'l R.R. Passenger Corp. · filed 2018-07-10(7), (8)

The defendant is correct that these claims are subject to a three-year statute of limitations under District of Columbia law. ... Here, the plaintiff testified that she learned of her termination, the injury for which she seeks relief in this case, on February 7, 2012. ... In light of this testimony, and the defendant's concession that the statute of limitations did not begin running until February 7, 2012, ... the Court concludes that the plaintiff was required to initiate her wrongful discharge and fraudulent and negligent misrepresentation claims on or before February 7, 2015. However, she did not file her Complaint until August 11, 2015, ... nearly six months after the statutory limitations period expired.

Section 12-301(7) supplies a three-year limitation period for simple contracts, running from accrual, and a timely suit by the assignor can arrest that period for an intervening assignee pursuing the assigned claim.

Fox-Greenwald Sheet Metal Co., Inc. v. Markowitz Bros., Inc., Continental Casualty Co., Blake Construction Co., Inc., United States of America · filed 1971-10-12(7)

The three-year period applied to suit on Fox-Greenwald’s note and, we may assume with the record devoid of anything to summon the longer period, to suit on the assigned debts of Markowitz as well. ... As to each, the statute started running when the cause of action arose, subject to arrest upon commencement of appropriate litigation. ... Fox-Greenwald’s suit against Markowitz, we hold, arrested the statute, not only for itself, but upon Blake’s intervention for the benefit of the latter as well. ... Rather, the three-year period applicable to “a simple contract, express or implied,” D.C.Code § 12-301(7) (1967), governed suit on the note.

Subsection (2) provides a three-year statute of limitations for the conversion claim.

Liberty Lobby, Inc. v. Anderson · filed 1983-03-31(2)

The alleged conversion took place in 1966. D.C.Code § 12-301(2) provides for a three-year statute of limitations. Plaintiff knew or should have known of the theft of the files since 1969, when the first article in True Magazine mentioned the theft. Carto was familiar with the contents of the article, as revealed by his filing of the subsequent libel suit against the article’s authors and publisher in 1970.

Section 12-301(4) requires a libel suit to be filed within one year after the alleged defamation.

Sturdivant v. Seaboard Service System, Ltd. · filed 1983-04-06(4)

A suit for libel must be filed within one year of the alleged defamation. See D.C.Code § 12-301(4) (1973). Since this aspect of the action was barred by the statute of limitations, the trial court properly granted summary judgment on this issue.

Section 12-301(8) sets a three-year limitations period for negligence actions, but equitable estoppel may prevent a defendant from invoking the period when the defendant's conduct lulled the plaintiff into inaction.

Wymer v. Lessin · filed 1985-12-20(8)

Dr. Chan has moved to dismiss the case against her since it was filed after the applicable three year statute of limitations for negligence action in the District of Columbia. See D.C.Code § 12-301(8) (1981). She argues that since the injury which is the source of this action occurred in March of 1981, the second suit, which was filed on June 14, 1985, is barred. ... Nonetheless, as the Ca,rter court noted, the courts have long recognized that the doctrine of equitable estoppel can be invoked to prevent an unjust application of the statute of limitations. ... Under that doctrine, a defendant cannot rely on the statute if his conduct has tended to lull the plaintiff into inaction, permitting the statute to run. ... Plaintiffs convincingly argue here that this doctrine should prohibit Dr. Chan from availing herself of the statute of limitations. ... As a consequence, the defendant should not be allowed to avail herself of the statute of limitations bar.

Section 12-301(7) supplies a three-year limitations period for contract actions and, by analogy, applies that period to claims under ERISA § 502 and LMRA § 301.

Trustees of the United Ass'n Full-Time Salaried Officers & Employees of Local Unions v. Steamfitters Local Union 395 · filed 1986-08-01(7)

... that D.C.Code § 12-301(7) is the applicable statute of limitations. That section provides a three-year limitations period for actions sounding in contract. By analogy, that provision properly applies to a claim under ERISA § 502 and LMRA § 301.

Section 12-301 imposes a three-year limitations period, and a claim cannot be dismissed as untimely on a motion to dismiss without evidence that the breach occurred more than three years before suit or that the plaintiff knew of the breach and failed to act within that period.

Abramson v. Wallace · filed 1989-01-30

Wallace also contends that plaintiff’s claims are barred under the District of Columbia three year statute of limitations governing all of the claims in this action. ... We agree. At this time there is nothing in the record that proves that the breach of this oral agreement occurred more than three years prior to the date this suit was filed, May 17, 1985, or that Abramson knew that the breach had occurred, but failed to take the appropriate action within that same time period. We are left with only conjecture, decline to draw the inference suggested by defendant, and, therefore, deny defendant’s motion to dismiss.

The three-year limitations period in § 12-301 applies to the claims, while a continuing wrong may toll accrual until the unlawful conduct ends.

Committee of Blind Vendors v. District of Columbia · filed 1990-04-17

On November 22, 1988, the Court held that the three-year statute of limitations found in D.C.Code § 12-301 applies to plaintiffs’ claims.

Section 12-301(8) imposes a three-year limitations period on rights of action for which no other limitation is specifically prescribed.

Rivers v. Montgomery · filed 1993-11-08(8)

Therefore, the applicable statute in this instance is the District of Columbia’s residual statute of limitations, D.C.Code § 12-301(8) (1981) which provides that “rights of action for which a limitation is not otherwise specifically prescribed is three years.”

Section 12-301(8)'s three-year limitations period does not apply to a trustee's federal bankruptcy claim under 11 U.S.C. § 726(b), rather than a state-law claim.

Guinee v. Toombs (In Re Kearing) · filed 1994-07-08(8)

Similarly, the cause of action brought by the trustee in this case arose post-petition, when it appeared that there would be an administrative insolvency and that Toombs, by virtue of being paid interim compensation, may have received a greater distribution as an administrative claimant than he is entitled to receive under section 726(b). Accordingly, section 108(a) does not apply in this case. Further, because the trustee’s cause of action arises under section 726(b) of the Bankruptcy Code, which provides for the pro rata payment of administrative claims, and not under state law, the three-year statute of limitations under D.C.Code § 12-301(8) does not apply. Therefore, the court concludes that this action is not barred by any statute of limitations, and that the trustee has until the close of the bankruptcy case to prosecute such actions.

Section 12-301(8) supplies a three-year limitations period when no other period is specially prescribed, while the twelve-year period for sealed instruments in section 12-301(6) does not apply to an unsealed arbitration decision.

Consolidated Rail Corp. v. Delaware & Hudson Railway Co. · filed 1994-11-18(8), (6)

This court finds that while the 1978 and 1979 agreements were made under seal, the USRA Decision which Plaintiff seeks to confirm was not. Accordingly, this court holds that the applicable statute of limitation is three years.

Section 12-301(8) supplies a three-year catch-all limitations period for claims for which no other limitation is specifically prescribed, and a later limitations statute cannot retroactively shorten that period for claims already accrued.

Owens-Corning Fiberglas Corp. v. Henkel · filed 1997-03-06(8)

Sections 12-301(8) and 12-311, read together, can reasonably be construed in a manner that avoids the harsh result which OCF asks us to impose. Generally, if a new statute of limitations does not specifically repeal an old one, then the old one controls actions which had already accrued where the new statute was enacted. ... Even if we assume, solely for the purpose of argument, and without deciding, that notwithstanding its essentially liberalizing design, Section 12-311 reduced the statutory limitations period in some cases from three years to one year, we conclude that this reduced period cannot reasonably be applied to a plaintiff whose right of action had already accrued by the time Section 12-311 became effective. ... Accordingly, we hold that even if Mr. Henkel’s loss of work in April 1986 constituted a disability within the meaning of Section 12-311(b) — a question which we do not decide — the Henkels’ complaint is not time-barred.

Section 12-301(8) supplies the residual three-year limitations period when an action is not otherwise specially governed by another statute.

District Cablevision Limited Partnership v. Bassin · filed 2003-07-17(8)

The plaintiffs’ claims therefore were not governed by the statute of limitations for breach of contract actions. As those claims also were not “specially” governed by any other statute of limitations, the residual clause of D.C.Code § 12-301(8) applied.

Section 12-301 does not protect a separate corporate body from the statute of limitations when its functions and activities are proprietary rather than governmental.

New 3145 Deauville, L.L.C. v. First American Title Insurance · filed 2005-08-25

However, subsequent to this determination by the trial court, we held in D.C. Water & Sewer Auth. v. Delon Hampton & Assocs., 851 A.2d 410, 416 (D.C.2004), that “functions and activities of WASA, a separate corporate body distinct from the District of Columbia, are proprietary in nature and thus beyond the protection of nullum tempus” and likewise of the exception in § 12-301. Thus, WASA is subject to the statute of limitations with respect to that portion of the outstanding debt of New Deauville to WASA to which the statute of limitations could constitute a defense.

Section 12-301(8) provides a three-year residual limitations period for personal injury claims in the District.

Turner v. District of Columbia · filed 2005-08-25(8)

Where state law provides multiple statutes of limitations for different kinds of personal injury actions, federal courts adjudicating § 1983 claims borrow the general or residual statute for personal injury actions. Owens v. U.U. Okure, 488 U.S. 235, 249-50, 109 S.Ct. 573, 102 L.Ed.2d 594 (1989). There is a three-year residual statute of limitations in the District for personal injury claims. D.C.Code § 12-301(8).

Section 12-301(4) imposes a one-year statute of limitations on assault and battery claims.

Carter v. Washington Metropolitan Transit Authority · filed 2006-09-06(4)

In the District of Columbia, the statute of limitations for assault is one year, as is the limitations period for battery. D.C.Code § 12-301(4) (2001).

Section 12-301(7) supplies a three-year limitations period for an ERISA § 502 benefits claim because the claim is analogous to a breach-of-contract action.

Walker v. Pharmaceutical Research & Manufacturers of America · filed 2006-11-15(7)

Because ERISA § 502 claims are most analogous to breach of contract claims, ... the applicable statute of limitations for this claim is three years. ... see D.C.Code § 12-301(7).

Section 12-301's limitations do not run against the District of Columbia when it is performing public functions.

Solid Rock Church, Disciples of Christ v. Friendship Public Charter School, Inc. · filed 2007-05-17

The law is settled that the District of Columbia, as a municipality, enjoys limited sovereign immunity from the operation of statutes of limitation under the common law doctrine of nullum tempus occurit regi (“no time runs against the sovereign”), and under D.C.Code § 12-301 (2001), while in the performance of public functions. ... This case is controlled by the principle that municipal property devoted to a public use may not be acquired by adverse possession and the doctrine of nullum tempus occurit regi (“no time runs against the sovereign”) is directly applicable.

Section 12-301 imposes a one-year limitations period on the common-law claims at issue, and concealment of a defendant’s identity does not toll that period under the lulling doctrine.

Hall v. Lanier · filed 2010-04-22

Davis argues that the plaintiffs claims of Assault (Count XIII), Battery (Count XIV), False Arrest (Count XVII), Defamation, Libel and Slander (Count XVIII), and Intentional Infliction of Emotional Distress (Count XIX) are barred by the District of Columbia’s one-year statute of limitations set forth at D.C.Code § 12-301. ... The plaintiff does not dispute that he had until November 15, 2007, one year from the arrest date of November 15, 2006, to file those claims against Davis, but he argues that the time for filing them should be equitably tolled under the doctrine of “lulling.” ... Therefore, the Court grants Defendant Davis’s motion to dismiss the aforementioned common law claims as time-barred.

Section 12-301 supplies the applicable statute of limitations that bars the plaintiff's Bivens claims against the unknown CIA agent.

Zhao v. Unknown Agent of the Central Intelligence Agency · filed 2010-12-03

Appellant’s *337claims under Bivens against the unknown CIA agent are barred by the applicable statute of limitations. See D.C.Code § 12-301; see also Wallace v. Kato, 549 U.S. 384, 388, 127 S.Ct. 1091, 166 L.Ed.2d 973 (2007) (“[I]t is the standard rule that accrual occurs when the plaintiff has a complete and present cause of action, that is, when the plaintiff can file suit and obtain relief.” (internal quotation marks, alterations and citations omitted)).

D.C. Code § 12-301 imposes a three-year limitations period on the negligence claims here, subject to tolling under the continuing-treatment rule until treatment of the specific matter ends.

Patteson v. Astrazeneca, LP · filed 2012-07-09

Under District law, Plaintiffs’ negligence claims are subject to a three-year statute of limitations. See D.C.Code § 12-301. Such a limitations period is subject to “the continuing treatment rule,” which tolls the period for filing suit for claims arising from a doctor’s treatment “until the doctor ceases to treat the patient in the specific matter at hand.”

Section 12-301(8) starts the limitations period for a negligence claim involving a foreign object left in a surgical wound when the patient knows or should know what happened, rather than when the object was left.

Burke v. Washington Hospital Center · filed 1968-12-06(8)

the patient becomes aware, or should have become aware of what had happened, and not at the moment when the surgeon closes the wound with the foreign object abandoned inside.

Section 12-301(4) gives assault and battery claims a one-year limitations period, measured from the injury rather than a decedent’s later death for survival actions.

Jacobs v. Experts, Inc. · filed 2016-09-15(4)

“The statute of limitations for a claim brought pursuant to the Survival Act is the statute of limitations applicable to the underlying claim, and the claim generally accrues on the date of the decedent’s injury, and not on the date of the decedent’s death.”

Section 12-301(4) imposes a one-year limit on battery actions, while § 12-301(8) supplies a three-year limit for negligence actions, including a physician’s negligent failure to disclose treatment risks.

Canterbury v. William Thornton Spence and the Washington Hospital Center, a Body Corporate · filed 1972-07-20(4), (8)

We now confront the question whether appellant’s suit was barred, wholly or partly, by the statute of limitations. The statutory periods relevant to this inquiry are one year for battery actions ... and three years for those charging negligence. For one a minor when his cause of action accrues, they do not begin to run until he has attained his majority. ... Appellant’s causes of action for the allegedly faulty laminectomy by Dr. Spence and allegedly careless post-operative care by the hospital present no problem. Quite obviously, each was grounded in negligence and so was governed by the three-year provision. ... That claim, like the others, was governed by the three-year period of limitation applicable to negligence actions ... and was ... unaffected by the fact that its alternative was barred by the one-year period pertaining to batteries.

Section 12-301(4) provides a one-year limitations period for libel, slander, assault, and battery, and that period also applies to dependent intentional-infliction-of-emotional-distress claims and conspiracies based on those torts.

Thomas v. News World Communications · filed 1988-02-23(4)

D.C.Code Ann. § 12-301(4) (1981) specifically provides a one-year limitations period “for libel, slander, assault, [and] bat-tery_” The one-year period has also been imposed to govern actions for torts, like the intentional infliction of emotional distress, that are dependent on “the same personal interests infringed by the intentional torts” expressly subject to § 12-301(4). ... Moreover, the limitations period governing plaintiffs’ claims of civil conspiracy is established by the statute of limitations governing the underlying tort. Thus, the complaint’s allegations of a conspiracy by the Times defendants to libel and assault plaintiffs are also subject to the one-year period set out in D.C.Code § 12-301(4).

Section 12-301(4) gives assault-and-battery claims a one-year filing period; an excessive-force claim based only on intentional police conduct falls under that period rather than the three-year catchall in § 12-301(8).

District of Columbia v. Tinker · filed 1997-03-13(4)

Preliminarily, we must decide whether Tinker’s assault claim is subject to a one-year or a three-year statute of limitations. D.C.Code § 12-301(4) sets a one-year limit on the time within which a plaintiff may file a civil action for assault and battery. D.C.Code § 12-301(8), on the other hand, states that the time for filing suit based on a cause of action “for which a limitation is not otherwise specifically prescribed,” which includes most negligence claims, “is three years.” ... Thus we conclude that the only tortious conduct alleged in the second count of the complaint and proved by Tinker at trial was assault and battery on the part of the police. It follows that his claim was subject to the one-year statute of limitations, D.C.Code § 12-301(4).

Section 12-301(4) requires a slander claim to be brought within one year after the action accrues.

Savoy v. VMT LONG TERM CARE MANAGEMENT CO., INC. · filed 2007-11-27(4)

Any claim under the D.C. Human Rights Act must be brought within one year of the unlawful discriminatory act, D.C.Code § 2-1403.16(a); any claim for slander must be brought within one year from the time the action accrues, D.C.Code § 12-301(4); and any Title VII complaint must be filed within ninety days of receipt of the Notice of Right to Sue.

Section 12-301(4) imposes a one-year limitations period for assault and battery actions, subject to tolling while the claimant is imprisoned when the right of action accrues; the period begins when the disability is removed and continues to run thereafter.

Jones v. Ritter · filed 2008-11-19(4)

Under District of Columbia law, an action for assault or battery may not be brought after the expiration of the one-year period “from the time the right to maintain the action accrues.” D.C.Code § 12-301(4). The limitations period is tolled, however, if “a person entitled to maintain an action is, at the time the right of action accrues[,] imprisoned,” and that person may “may bring action within the time limited after the disability is removed.” D.C.Code § 12-302(a). A prisoner’s disability is removed at the instant he is released from custody, at which time the statute of limitations begins to run and continues to run even if the prisoner subsequently is arrested or imprisoned. See Arnold v. District of Columbia, 211 F.Supp.2d 144, 147-49 (D.D.C.2002); District of Columbia v. Tinker, 691 A.2d 57, 64 (D.C.1997).

Section 12-301(8) imposes a three-year limitations period for legal-malpractice claims, subject to the continuous-representation rule.

Hiligh v. Sands · filed 2019-06-10(8)

District of Columbia law provides a three-year statute of limitations for legal malpractice claims.

Section 12-301(1) gives a vendor’s lien the limitations period applicable to recovery of land rather than the three-year period for contractual debts.

Jackson v. Cash · filed 2021-04-01(1)

Therefore, the right to recover under the theory of a vendor’s lien is not barred by the statute of limitations.

Section 12-301(8) provides a three-year limitations period for an action lacking another specifically prescribed limitation; for a partnership-accounting action, the period runs only after sufficient time following demand to permit compliance.

Warren v. Chapman · filed 1987-12-09(8)

Accordingly, we hold that where a demand for an accounting has been made in connection with the dissolution of a partnership, the limitations period commences to run for an action between the partners for an accounting and settlement only after a sufficient time has elapsed after such demand to enable those on whom it has been made to comply. ... Consequently, Chapman’s suit was timely filed, D.C.Code § 12-301(8), twelve months later.

Section 12-301(7)'s three-year limitations period begins when a contract claim becomes actionable, so if the parties make an actual demand a prerequisite to suit, the period starts when that demand is made.

n.sidney Nyhus v. Travel Management Corporation · filed 1972-08-11(7)

Should a jury so find as a matter of fact, a demand was prerequisite to a right of action and the statute of limitations commenced running only from the time it was made.