N.J. Stat. Ann. § 2A:14-1

Section 2A:14-1’s six-year limit does not apply to an officer’s liability for loans to corporate stockholders when that liability rests solely on statute.

United States v. Jacobs · filed 1957-04-05

Petitioner’s final proposition is that the instant suit is “an action on the case”, and so governed by the New Jersey six year statute of limitations. (Although the New Jersey six year statute of limitations, N.J.S.A. 2A:14-1, does not refer to “action upon the case”, its predecessor statute, R.S. 2:24-1, did refer to actions upon the case.) But the relevant point is that New Jersey’s general statute of limitations is not the one applicable to the present action.

Section 2A:14-1 applies only to actions at law and cannot be invoked to bar a claim for equitable relief.

Farbenfabriken Bayer, A.G. v. Sterling Drug, Inc. · filed 1957-07-15

The bar of the statute of limitations may not be invoked as a defense against the plaintiff’s claim for equitable relief. The statute of limitations, by its express terms, applies only to actions at law.

Section 2A:14-1’s six-year period for contract claims does not apply to a personal injury claim based on unseaworthiness, even when framed as breach of an implied warranty.

Oroz v. American President Lines, Ltd. · filed 1958-09-30

Plaintiff urges that the warranty of seaworthiness should be treated as an implied contract and consequently that the applicable New Jersey statute is N.J.S.A. 2A:14-1, which permits six years for bringing a contractual claim, express or implied. We agree with the district court, however, that the six year statute does not apply, and that the governing statute is the New Jersey two-year provision, N.J.S.A. 2A:14-2.

Section 2A:14-1’s six-year limit does not apply to a claim for personal injuries merely because the claim is based on a contract.

Atlantic City Hospital v. Finkle · filed 1970-05-21

Defendant resists the motion first on the claim that since the first count arises out of contract, the six-year statute, N.J.S.A. 2A:14-1, which governs "recovery upon a contractual claim," applies. This argument is not sustainable because whether the six-year statute or the two-year statute designates the applicable limitation depends on the nature of the injuries, not the theory of recovery.

Section 2A:14-1's six-year limitations period does not apply to treble-damages actions under Section 4 of the Clayton Act.

Farbenfabriken Bayer, A. G. v. Sterling Drug Inc. · filed 1961-07-27

It was therein decided that Section 2A:14-1 was not applicable to an action for treble damages under Section 4 of the Clayton Act, supra. ... We are of the opinion that the claim for treble damages was properly dismissed on the earlier motion of the defendant; however, the opinion of the Court is modified to reflect the applicability of Section 2A: 14-10, supra.

Section 2A:14-1’s six-year limitations period does not bar a trustee’s claim for corpus commissions merely because the trustee did not file an accounting within six years.

In Re Bessemer Trust Company · filed 1976-12-10

If an inter vivos trust indenture, such as exists in these trusts, is construed as a contract and thereby requires a trustee of such a trust to file an accounting every six years or be barred under N.J.S.A. 2A:14-1 from claiming corpus commissions for the elapsed period, such a construction would subject such trustees to a duty that even the court deciding Donaldson said they did not have, 88 N.J. Super. at 595, and would expose the beneficiaries to added expense for such accountings. ... The court concludes that BTC's claim for corpus commissions are not barred by the six-year statute of limitations.

Section 2A:14-1 gives contractual claims a six-year limitations period, which applies to a union’s action to enforce an arbitration award against an employer.

Hotel & Restaurant Employees & Bartenders International Union, Local 54 v. Ramada, Inc. · filed 1986-01-09

The New Jersey statute of limitations for contractual claims is six years, N.J.S.A. 2A:14-1, and this period has not yet run. Accordingly, defendant’s motion to dismiss shall be denied.

Section 2A:14-1’s six-year limitations period does not apply to claims for breach of a contract for sale governed by N.J.S.A. 12A:2-725.

Foodtown v. Sigma Marketing Systems, Inc. · filed 1981-07-23

Plaintiff’s contention that the six-year statute of limitations pursuant to N.J.S.A. 2A:14-1 is applicable to the breach-of-contract claims is clearly without merit.

The six-year period for contract actions does not apply to a § 301 claim that challenges an arbitration award, even when the employee sues the union or seeks damages.

Walsh v. Boss Linco Lines, Inc. · filed 1981-11-18

Plaintiff claims the suit was timely filed, applying the six-year statute of limitations appropriate to contract actions N.J.S.A. 2A:14-1. ... It is the nature of the cause of action, not the identity of the defendant which controls the choice of limitation statutes. ... Based upon the two cases cited the court concludes that Walsh’s claim under § 301 is time barred and summary judgment is appropriate.

Section 2A:14-1 governs legal replevin actions; equitable replevin is governed by laches, with regard to the statute's policy.

Desiderio v. D'AMBROSIO · filed 1983-06-08

The statute of limitation, which governs a legal replevin action, N.J.S.A. 2A:14-1, is by its terms applicable only to an "action at law"; chancery applies the doctrine of laches in its stead, Jersey City v. Jersey City Water Supply Co., 90 N.J. Eq. 14, 18 (Chan. 1918), aff'd o.b. 90 N.J. Eq. 603 (E. & A. 1919), although a court of equity will not ignore the spirit and policy of the statute.

The six-year limitations period does not govern a commercial buyer’s claim for economic loss from defective goods against an immediate seller or remote supplier; the U.C.C.’s four-year period governs.

Spring Motors Distributors, Inc. v. Ford Motor Co. · filed 1985-03-28

Accordingly, the four-year period of limitations provided by the Code, N.J.S.A. 12A:2-725, not the six year general statute of limitations, N.J.S.A. 2A:14-1, determines the time within which an action must be commenced against the immediate seller and remote supplier.

Section 2A:14-1 provides a six-year residual limitations period, but it does not govern personal injury claims or supply the limitations period for § 1983 claims.

Cito v. Bridgewater Township Police Department · filed 1989-12-18

In light of the New Jersey Supreme Court’s construction of its own state’s statute, New Jersey’s six-year residual statute is not the residual personal injury statute to which the Owens holding must be applied; its two-year residual statute is.

Section 2A:14-1 provides a six-year residual limitations period but does not apply to personal injury claims.

Cito v. Bridgewater Township Police Department · filed 1990-01-12

Appellants are correct that N.J.S.A. 2A: 14-1 is a residual statute, but incorrectly argue it applies to personal injury claims.

The six-year period does not apply to claims for personal injuries, even when pleaded as breach of contract or interference claims.

Montells v. Haynes · filed 1992-07-31

However, she asserts that in her complaint she alleges breach of contract, tortious interference with contract and prospective economic advantage, which she alleges are covered by the six-year statute, N.J.S.A. 2A:14-1. We disagree. These claims are based on the direct conduct of defendants and the injuries she alleges she suffered are personal in nature. The two-year statute of limitations applies where the gravamen of plaintiff's complaint is injury to the person.

Section 2A:14-1 generally sets a six-year limit for conversion of stock shares, but it does not govern claims arising from wrongful appropriation of cooperative housing interests.

Estate of Ahrens v. Edgewater Colony · filed 1993-08-12

Although stock shares are generally considered as personal property and claims alleging their conversion are generally covered by N.J.S.A. 2A:14-1, the six-year statute of limitations, plaintiffs' claims for damages are really actions at law relating to wrongful appropriation of land, also governed by N.J.S.A. 2A:14-7, the twenty-year statute.

The six-year contract limitations period does not apply to a warranty arising from a sale of goods when repair services are incidental to the sale.

Docteroff v. Barra Corp. · filed 1995-06-21

We agree with the motion judge that this case is governed by the four-year UCC statute of limitations, N.J.S.A. 12A:2-725, and not the six-year statute governing contract claims, N.J.S.A. 2A:14-1.

Section 2A:14-1’s six-year period applies to legal malpractice claims whose primary injury is economic, but not to claims for personal injuries arising from a criminal prosecution.

McGrogan v. Till · filed 2000-02-01

We also conclude, as an alternative ground for our affirmance of the judgment, that the two-year limitations period applies. ... The six-year statute has been applied to legal-malpractice actions in which the primary injury is economic. ... We are persuaded that the consequences of Till's alleged malpractice qualify as personal injuries.

Section 2A:14-1’s six-year period does not govern a parishioner’s breach-of-fiduciary-duty claim against a pastor who provided counseling; the two-year personal-injury period applies.

Balliet v. Fennell · filed 2004-03-30

The issue in this case is whether plaintiff's cause of action for breach of fiduciary duty by his pastor is governed by N.J.S.A. 2A:14-1 [1] or N.J.S.A. 2A:14-2. [2] We hold that the cause of action pled by plaintiff is governed by N.J.S.A. 2A:14-2 and affirm.

Section 2A:14-1 gives a plaintiff six years to recover unpaid commissions on a breach of contract claim; commissions due before that period cannot be awarded.

Doynow Sales Associates, Inc. v. Rocheux International of New Jersey, Inc. · filed 2009-08-24

If the jury finds for DSA on the issue of commission reductions, it may not award damages for any commissions "due prior to September 17, 2002” (DSA Opp. Br. at 16), because the instant complaint was filed on September 17, 2008 ... and the New Jersey statute of limitations for breach of contract claims is six years. See N.J. Stat. Ann. § 2A:14-1 (2009).

The six-year limitations period does not apply to a false light invasion of privacy claim grounded in defamatory allegations.

Swan v. Boardwalk Regency Corp. · filed 2009-05-07

Neither law nor logic justifies why Count Two of plaintiff's complaint labeled "Defamation" should be subject to a one-year statute of limitations while his same claims re-labeled "False Light/Invasion of Privacy" in Count Three should be governed by a longer limitations period.

The six-year limitations period excludes personal injury actions, including a breach of fiduciary duty treated as a personal injury claim.

Thomas v. Care Plus of New Jersey, Inc. · filed 2012-06-08

At least one of the statutes upon which he relies, however, explicitly excludes personal injury actions from the six-year limitations period. ... Having so assumed, we agree with the District Court that breach of this kind of “fiduciary relationship” is akin to a personal-injury action, which (as above) is governed by a two-year statute of limitations.

Section 2A:14-1 provides a six-year limitations period for conversion and trespass claims.

Frankentek Residential Systems, LLC v. Buerger · filed 2014-04-24

In New Jersey, the limitations period for both conversion and trespass is six years. N.J. Stat. Ann. § 2A:14-1.

Section 2A:14-1 provides a six-year limitations period for TCCWNA and Consumer Fraud Act claims.

Martinez-Santiago v. Public Storage · filed 2014-08-14

Plaintiffs claims are governed by a six-year statute of limitations, N.J.S.A. 2A:14-1, and are timely.

Section 2A:14-1 provides a six-year limitations period for New Jersey breach of contract actions; that period can be borrowed for an ERISA benefits claim when a plan’s filing deadline is set aside.

Mirza v. Insurance Administrator of America, Inc. · filed 2015-08-26

We will instead borrow the statute of limitations from the most analogous state-law claim, which the parties agree is New Jersey’s six-year deadline for breach of contract actions. See N.J. Stat. Ann. § 2A:14-1; Hahnemann Univ., 514 F.3d at 305-06. Mirza filed his complaint on March 8, 2012, well before the six-year limitations period for breach of contract expired.

Section 2A:14-1 gives six years to bring claims for breach of contract or the covenant of good faith and fair dealing.

BOROUGH OF WEST WILDWOOD VS. HERBERT C. FREDERICK,ET AL. VS. MUNICIPAL EXCESS LIABILITY JOINT INSURANCE FUND (C-0057-13, · filed 2017-07-14

Because the facts alleged in counts one and two establish plaintiff filed his complaint well beyond the six-year limitations period, N.J.S.A. 2A:14-1, those counts were properly dismissed by the court for failing to state a claim upon which relief could be granted under Rule 4:6-2(e).

The six-year period for injury to another’s rights does not apply when the claim is, in substance, for personal injury governed by the two-year limitations period.

Andreyko ex rel. Estate of Andreyko v. Sunrise Senior Living, Inc. · filed 2014-01-24

In sum, Plaintiff argues that her self-characterized claim for “neglect and mistreatment,” (Opp. Br. at 5-6), is premised on the rights afforded via the NHRRRA and should therefore be subject to the six-year statute of limitations provided by N.J.S.A. § 2A:14-1 “for any tortious injury to the rights of another not stated in sections 2A:14-2 and 2A:14-3.” However, N.J.S.A. § 2A:14-2 explicitly provides for a two-year statute of limitations for wrongful acts, neglect, or default — which are exactly the harms Plaintiff alleges in her description of her claims as for “neglect and mistreatment.” Her characterization of the resultant damages as arising from the NHRRRA rather than in personal injury is inapposite to the essence of the action which arises from bruising on or around January 2009.

The six-year limitations period does not apply to collection claims arising from store credit cards usable only at the issuing retailer; those claims are subject to the four-year period for contracts for sale.

Midland Funding LLC Current Assignee, Etc. v. Bruce Thiel Midland Funding LLC Current Assignee, Etc. v. Luisa · filed 2016-08-29

Plaintiff Midland Funding LLC, an assignee of the financial institutions that issued credit cards to store customers on behalf of retailers, argues the six-year statute of limitations that governs most contractual claims, N.J.S.A. 2A:14-1, is applicable under the circumstances presented, while defendants in each action, as well as amici curiae Consumer League of New Jersey and National Association of Consumer Advocates, argue the four-year statute of limitations, which governs contracts relating to the sale of goods, N.J.S.A. 12A:2-725, should control. ... Having considered the parties' arguments, we hold that claims arising from a retail customer's use of a store-issued credit card — or one issued by a financial institution on a store's behalf — when the use of which is restricted to making purchases from the issuing retailer are subject to the four-year statute of limitations set forth in N.J.S.A. 12A:2-725.

The six-year limitations period for contract actions does not govern an action in lieu of prerogative writs, which is subject to Rule 4:69-6's forty-five-day limit.

ANDREW K. BONNER, JR. VS. CUMBERLAND REGIONAL HIGH SCHOOL (L-860-14, CUMBERLAND COUNTY AND STATEWIDE) · filed 2017-06-27

The Borough alternatively argues that AvalonBay's action is barred by the six-year statute of limitations that applies to contract actions. N.J.S.A. 2A:14-1. ... However, the present action does not assert a claim for breach of contract.

Section 2A:14-1 provides a six-year statute of limitations for contract claims.

FILGUEIRAS v. MIDLAND FUNDING, LLC · filed 2024-04-18

Under New Jersey law, a four-year statute of limitations governs claims involving the sale of goods, see N.J.S.A. § 12A:2–725, and a six-year statute of limitations governs contract claims, see N.J.S.A. § 2A:14–1.

Section 2A:14-1(a) gives a bondholder six years from the bonds' maturity to file a breach-of-contract claim for payment.

Albasir v. City of Hoboken · filed 2024-11-19(a)

Here, the bonds matured on June 1, 1997. Therefore, plaintiff had to file an action by June 1, 2003.

Section 2A:14-1's six-year limitations period does not apply to claims under the New Jersey Civil Rights Act.

Pa Builders, LLC v. Township of Toms River · filed 2025-05-07

Plaintiffs raise two arguments in reply. First, plaintiffs argue that the six-year statute of limitation under N.J.S.A. 2A:14-1, not the two-year statute of limitation under N.J.S.A. 2A:14-2, applies to their claims, and, thus, they successfully filed within the appropriate statutory period. Alternatively, plaintiffs contend that, even if N.J.S.A. 2A:14-2 applied, they filed within the appropriate timeframe because the underlying tortious act—defendants Chankalian and Birkhead demanding plaintiffs elevate the home before it could be sold—did not occur until 2022. We are unpersuaded by plaintiffs' arguments. ... Plaintiffs' claims arising under the NJCRA are subject to a two-year statute of limitation.

Section 2A:14-1’s six-year limitations period does not apply when an easement holder seeks to exercise rights under a granted easement.

Bliesmann v. Duda · filed 2024-04-29

Plaintiffs are attempting to exercise their rights as easement holders, which does not implicate N.J.S.A. 2A:14-1.

Section 2A:14-1 imposes a six-year limit on civil fraud claims; adding those claims after the period expires is futile.

Soumphonphakdy v. Englewood Hospital and Medical Center · filed 2025-10-28

Third, the court found plaintiff's claims of civil fraud against the proposed defendants were time-barred, as more than six years had passed since his visit to the EHMC emergency department and the interpretation of his CT scans. Thus, the court concluded permitting plaintiff to file the amended complaint would be futile. We have reviewed the record and find no basis on which to conclude the motion court mistakenly exercised its discretion.

Section 2A:14-1 sets a six-year limitations period for contract-based claims, including legal malpractice, breach of fiduciary duty, and negligent misrepresentation.

Myers v. Benucci · filed 2026-03-03

Contract claims, including legal malpractice, breach of contract, fraudulent misrepresentation, and implied covenant of good faith and fair dealing, promissory estoppel, breach of fiduciary duty, and negligent misrepresentation are governed by N.J.S.A. 2A:14-1, which imposes a six-year statute of limitations.

Section 2A:14-1(a) gives a plaintiff six years to bring a breach of contract claim; the period began when the repudiated agreement was breached.

PINTO · filed 2026-03-17(a)

Accordingly, the Court finds that this action was filed outside of New Jersey’s six-year statute of limitations for contract actions. N.J. Stat. Ann. § 2A:14-1(a).

Section 2A:14-1 gives a party six years from accrual to bring a breach of contract claim, and the continuing violation doctrine does not extend that period.

Estate of Mohamed J. Kazan v. the Grill House, Inc. · filed 2026-04-01

Under N.J.S.A. 2A:14-1, the statute of limitations for a breach of contract claim "commence[s] within six years next after the cause of any such action shall have accrued." ... We decline to extend the doctrine to a breach of contract claim. ... Accordingly, Grill House's claim regarding plaintiffs' failure to repair and maintain the premises that predate March 28, 2016 was barred by the statute of limitations.

The six-year limitations period for general contracts does not apply to a deposit agreement tied to a sale of goods; the four-year period for sales of goods applies.

Silver Lining Enterprises, LLC v. New Gen Enterprises · filed 2025-11-25(a)

The claim for breach of the Deposit Agreement cannot be resolved without considering the contract for sale as plaintiff’s cause of action only arises from defendant’s alleged failure to deliver the goods in the purchase orders. Accordingly, the four-year statute of limitations in § 12A:2–725 applies to both the Deposit Agreement and the purchase orders.

Section 2A:14-1’s six-year limitation bars a Clayton Act treble-damages action filed more than six years after the cause of action arose.

Gordon v. Loew's Inc. · filed 1957-07-31

In the action brought by John, Helen and Joseph Gordon it appears from the face of their complaint that the cause of action sued upon arose more than six years before the complaint was filed. ... It is therefore, perfectly clear that their suit is barred by section 2A:14-1 ... if not by section 2A:14-10.

Section 2A:14-1 provides a six-year limitations period that the court applied in assessing whether the action was timely.

Todd Shipyards Corp. v. Moran Towing & Transportation Co. · filed 1957-09-09

One month later Todd brought this action. This was well within the applicable six-year New Jersey Statute of Limitations. N.J.S.A. 2A:14-1.

Section 2A:14-1 provides a six-year limitations period for Clayton Act treble-damages actions unless the two-year limit for actions on penal statutes applies.

Frank I. Gordon and Marion V. Gordon v. LOEW'S Incorporated · filed 1957-09-16

Upon examining these statutes we observe that the period of limitation applicable to the actions here in question is six years, as provided by section 2A:14-1 unless the plaintiffs' actions for treble damages under section 4 of the Clayton Act are to be regarded as actions brought for a forfeiture upon a penal statute within the meaning of section 2A:14-10, in which case the limitation of two years provided by that section is applicable.

Section 2A:14-1 provides a six-year limitations period for a union duty-of-fair-representation claim characterized as an injury to another’s rights.

Tuma v. American Can Company · filed 1973-04-26

This Court chooses to apply the latter six-year limitations period. If this Court were to characterize the unfair representation claim as a claim in tort, it would not consider it in the nature of the classical “injury to the person caused by wrongful act,” but rather, more appropriately, a “tortious injury to the rights of another” not included within the above classical personal injury concept.

Section 2A:14-1 gives a plaintiff six years to bring a claim for lost wages caused by a union’s alleged breach of its duty of fair representation.

Brown v. College of Medicine and Dentistry · filed 1979-03-21

That loss, although allegedly tortiously sustained, fits squarely within the provision of N.J.S.A. 2A:14-1 which governs actions "for any tortious injury to the rights of another." ... This court, therefore, concludes that the suit was timely filed according to the six-year limitations period set out in N.J.S.A. 2A:14-1.

Section 2A:14-1 provides a six-year limitations period for this damage claim.

Todd Shipyards Corporation v. Moran Towing & Transportation Co., Inc. · filed 1957-09-09

One month later Todd brought this action. This was well within the applicable six-year New Jersey Statute of Limitations. N.J.S.A. 2A:14-1.

Section 2A:14-1’s six-year limitations period applies to a New Jersey corporation suing in New Jersey even when its other ties to the state are slim.

Birnberg v. Rancho La Costa (In re Reach, McClinton & Co.) · filed 1989-06-09

The court concludes that the New Jersey Supreme Court would conclude that a corporate plaintiff which is incorporated in New Jersey is entitled to rely on New Jersey’s applicable statute of limitations when filing a suit in New Jersey, notwithstanding the fact that the corporate plaintiff’s other ties to New Jersey may be slim. ... Accordingly, the court finds that New Jersey’s six-year statute of limitations applies to this case, and thus summary judgment is inappropriate.

Section 2A:14-1 provides a six-year limitations period for tortious interference claims against dealers who were not parties to the sales contract.

Custom Com. Eng. v. JOHNSON · filed 1993-12-30

The dealers were not parties to the Custom-Johnson agreement and thus could not breach it. Moreover, the dealers' alleged tortious conduct did not involve a "transaction in goods" between merchants under Article 2 of the UCC. ... Therefore, the six-year statute of limitations under N.J.S.A. 2A:14-1 controls.

Section 2A:14-1 provides a general six-year limitations period for the claims the court found were governed by it.

Fraser v. Bovino · filed 1998-12-11

With the exception of the RICO claim contained in the second count, the remaining claims are controlled by the general six-year statute of limitations set forth in N.J.S.A. 2A:14-1. ... The Gelnaw complaint was not filed until April 25, 1997, well beyond any conceivable statutory deadline.

Section 2A:14-1 provides a six-year limitations period for a court claim against a union for breach of the duty of fair representation.

Farber v. City of Paterson · filed 2004-06-07

Because that injury is “not stated in sections 2A14-2 and 2A:14-3,” the limitations period supplied by § 2A:14-1 applies.

Section 2A:14-1 sets a six-year limitations period for claims including breach of contract and fraud; dismissal is premature when facts affecting when the claims accrued remain unresolved.

Fox v. Congress Financial Corp. (In Re Target Industries, Inc.) · filed 2005-07-11

In New Jersey, causes of action for breach of contract, fraud and others are governed by a six year statute of limitations. ... Ultimately, either party may be proven correct as discovery proceeds. However, the determination of these matters of fact are beyond the scope of this motion. Therefore, Congress’ statute of limitations defense is premature.

Section 2A:14-1 sets a six-year limitations period that runs from the accrual of a claim.

Blystra v. Fiber Tech Group, Inc. · filed 2005-12-29

As held above, Blystra’s claims accrued on June 24, 1994. Blystra filed his complaint on September 18, 2000, beyond the six year limit. N.J. Stat. Ann. § 2A:14-1.

Section 2A:14-1 gives six years to bring contract or injury-to-real-property claims; where the parties agreed that the period would begin at substantial completion, the court measured the six years from that date.

Trinity Church v. Lawson-Bell · filed 2007-06-27

In other words, the clause defines the limitations period as commencing upon the date of issuance of the certification of substantial completion of the structure. Hence, at the latest, any lawsuit must be commenced within six years of that date since that is New Jersey's statute of limitations for lawsuits based on contracts or injury to real property. N.J.S.A. 2A:14-1.

Section 2A:14-1 provides a six-year limitations period for the claims the court considered, including contract, unjust enrichment, fraud, and negligent supervision claims.

Agere Systems, Inc. v. Advanced Environmental Technology Corp. · filed 2008-05-14

Under New Jersey law, Counts III, IV, V, VI, VII, VIII, IX, and X are governed by a six-year limitations period.

Section 2A:14-1 sets a six-year deadline for the claims the court found subject to it; claims that accrued more than six years before suit are untimely.

Rickenbach v. Wells Fargo Bank, N.A. · filed 2009-06-22

By contrast, Plaintiff Rickenbach’s other causes of action, all parties agree, are subject to the six year statute of limitation in N.J. Stat. Ann. § 2A:14-1. ... It being evident that Plaintiff Rickenbach’s cause of action accrued over six years before bringing suit, the Court will dismiss those claims subject to the six year statute of limitation — negligence, breach of duty of good faith and fair dealing, unfair and deceptive assessment and collection of fees, and violations of the Fair Foreclosure Act, New Jersey State Court Rules, New Jersey Consumer Fraud Act, and Truth-in-Consumer Contract, Warranty and Notice Act — as to Defendant Zucker and Defendants Wells and MERS.

Section 2A:14-1 provides a six-year limitations period for breach of contract and fraud claims in New Jersey.

Chen v. Inteplast Group, Ltd. · filed 2014-03-31

The Court takes judicial notice of the relevant limitations periods in New Jersey, which are six years for both breach of contract and fraud claims.

Section 2A:14-1 gives the state-law claims at issue a six-year filing deadline.

George v. East Orange Housing Authority · filed 2017-04-24

As the District Court observed, the claims that George’s complaint arguably raised against the East Orange parties have a six-year filing deadline. See N.J. Stat. Ann. § 2A:14-1.

Section 2A:14-1 imposes a six-year limitations period on breach of contract, conversion, and breach of fiduciary duty claims involving economic loss.

THE ESTATE OF STANLEY J. WARNER VS. KITTY FAN KOO (C-000205-16, BERGEN COUNTY AND STATEWIDE) · filed 2018-10-25

We find no error in applying the six-year statute of limitations here to dismiss the breach of fiduciary duty, breach of contract and conversion claims.

Section 2A:14-1 gives a claimant six years to bring a contract claim after it accrues.

THE LOFT COMMONS CONDOMINIUM ASSOCIATION, INC. VS. CHUANRUN CHEN (L-1211-16, PASSAIC COUNTY AND STATEWIDE) · filed 2019-03-05

We also agree defendant's claim was stale under the six-year statute of limitations. N.J.S.A. 2A:14-1.

Section 2A:14-1 provides a six-year limitations period for personal actions.

Vanz, LLC v. PMD Financial Group, LLC, et al. · filed 2019-03-28

Accordingly, the New Jersey District Court would have applied New Jersey’s six-year statute of limitations for personal actions to determine whether those claims were timely filed.

Section 2A:14-1 requires a plaintiff to file within six years after a claim accrues.

GATEWAY 2001, LLC VS. SANFORD WEISS (C-000044-12, HUDSON COUNTY AND STATEWIDE) · filed 2019-07-22

N.J.S.A. 2A:14-1 applies to plaintiffs' claims. Under this "tort-based property-damage" statute of limitations, a plaintiff must commence a lawsuit within six years after the cause of action has accrued.

Section 2A:14-1 gives legal malpractice and contract claims a six-year limitations period.

HERRON v. GURALNICK · filed 2020-06-30

In New Jersey, the statute of limitations for legal malpractice and contract actions is six years. ... Given that Plaintiff was last represented by Defendant Guralnick in 2012 and the train accident occurred in 2008, Plaintiff, who did not file this case until September 2019, missed the statute of limitations for all of his potential claims.

Section 2A:14-1 sets a six-year limitations period for the contract, implied-covenant, and fraud claims addressed by the court.

DUNHAM v. WELLS FARGO BANK · filed 2020-09-18

Under New Jersey law, Ms. Dunham’s claims are subject to a six-year statute of limitations. ... Here, Ms. Dunham’s causes of actions are based on events that occurred in or before 2009 (i.e., an alleged payment for a title search and $32,000 in excessive charges imposed by Wells Fargo), and, as such, her claims are barred by the six-year statute of limitations that expired in 2015.

Section 2A:14-1 provides a six-year limitations period for fraud and related tort claims; the period begins when the plaintiff knows or reasonably should know the basis for the claim.

EMERSON RADIO CORPORATION v. YU · filed 2020-10-01

Under New Jersey law, the statute of limitations for fraud, related torts, and unjust enrichment is six years. N.J. Stat. § 2A:14-1. ... As more than six years passed before Plaintiff filed suit in July 2020, claims based on the alleged “obligation” misrepresentation are precluded by the statute of limitations.

Section 2A:14-1 provides a six-year limitations period for breach of contract, breach of the implied covenant of good faith and fair dealing, and unjust enrichment claims.

BLUEGILL ASSET MANAGEMENT LLC v. AMERICAN REPROGRAPHICS COMPANY, LLC · filed 2021-01-19

As the parties recognize, a six-year statute of limitations applies to each claim.

Section 2A:14-1(a) sets a six-year limitations period for contract and fraud claims.

Rogalski v. Laureate Education Inc · filed 2023-04-11(a)

LEI argues based on the pleaded chronology that Rogalski’s claims are time-barred under N.J.S.A. § 2A:14-1(a)—New Jersey’s six-year statute of limitations for contract- and fraud-based claims. ... We agree.

Section 2A:14-1 applies a six-year limitations period to claims for breach of contract, fraud, conversion, unjust enrichment, misappropriation of intellectual property, and breach of the implied covenant of good faith and fair dealing.

LANCE H. STARK VS. JAMES MARAVENTANO, SR. (L-0028-18, HUNTERDON COUNTY AND STATEWIDE) · filed 2021-10-21

Plaintiff 's complaint alleges causes of action for breach of contract, fraud, misappropriation of intellectual property, unjust enrichment, conversion and breach of the implied covenant of good faith and fair dealing. Each is subject to N.J.S.A. 2A:14-1's six-year statute of limitations.

Section 2A:14-1 imposes a six-year limitations period on breach of contract, conversion, breach of fiduciary duty, and unjust enrichment claims.

GREENSTAR, LLC, HOMETOWN COFFEE, LLC v. ALBERT K. MARMERO, ESQUIRE (L-1384-18, GLOUCESTER COUNTY AND STATEWIDE) · filed 2022-10-05

Breach of contract, conversion, breach of fiduciary duty, and unjust enrichment claims are all governed by a six-year statute of limitations.

Section 2A:14-1 gives New Jersey tort claims a six-year limitations period; claims filed more than six years after the plaintiffs knew the underlying facts are time-barred.

Johnson v. Nextel · filed 2019-02-28

Their individual New Jersey tort claims are subject to a six-year statute of limitations.

Section 2A:14-1 provides a six-year limitations period for common law fraud claims.

BARBEE v. AMIRA NATURE FOODS, LTD. · filed 2023-07-19

As a preliminary matter, the Court agrees with Barbee that the appropriate statute of limitations period is six years. Ud. at 30); N.J. Stat. Ann. § 2A:14-1 (West 2022). Because Wacha does not substantively contend that Barbee’s allegations against him fall outside the six-year period, the Court declines to dismiss Barbee’s common law fraud claim on timeliness grounds.

Section 2A:14-1 requires covered actions to be commenced within six years after the cause of action accrues.

Angrisani v. Kevin M. Costello, Esq. · filed 2023-12-06

Thus, because plaintiff dismissed his claim against FTV on September 24, 2010, via stipulation of dismissal, he had until September 24, 2016, to sue defendants for malpractice based on the allegedly insufficient settlement. However, plaintiff did not file his legal malpractice complaint until August 17, 2018, approximately eight years after the accrual of his cause of action and almost two years beyond that applicable statute of limitations. Therefore, plaintiff's insufficient settlement claim was plainly time-barred. McGrogan, 167 N.J. at 419; N.J.S.A. 2A:14-1.

Section 2A:14-1 requires the listed claims to be brought within six years after they accrue.

Hood v. Matt Blatt, Inc. · filed 2024-02-07

Plaintiff was required to bring her claims of Consumer Fraud Act violations, negligent misrepresentation, equitable fraud and breach of implied covenant of good faith and fair dealing within six years of when they accrued. N.J.S.A. 2A:14-1; Catena v. Raytheon Co., 447 N.J. Super. 43, 52 (App. Div. 2016).

Section 2A:14-1(a) bars an action more than six years after the cause of action accrues, measured from when the injured party knew or reasonably could have discovered the injury.

Spalter v. Protective Life Insurance · filed 2024-02-16(a)

But it is barred by the New Jersey six-year statute of limitations beginning “after the cause of any such action shall have accrued.” N.J.S.A. § 2A:14-1(a); see also Crest-Foam Corp. v. Aetna Ins. Co., 727 A.2d 1030, 1034 (N.J. App. Div. 1999). New Jersey starts the limitations clock when “the injured party knows, or, with the exercise of reasonable diligence, could have discovered the injury.” Sodora v. Sodora, 768 A.2d 840, 842 (N.J. Super. Ct. Ch. Div. 2000). Spalter learned of the alleged miscalculations in 2009, the first time he received a grace notice. And in each of the 50 grace notices after that. All warned that his Lapse Protection Account was underfunded, and the early notice places his claim well beyond the six-year statute of limitations.

Section 2A:14-1 provides a six-year limitations period for CFA claims arising from the sale of merchandise.

Ms Services, LLC v. Calabria · filed 2024-02-26

Generally, the six-year statute of limitations under N.J.S.A. 2A:14-1 governs "CFA claims arising out of the sale of merchandise."

Section 2A:14-1(a) sets a six-year limit for actions based on contractual claims or liabilities.

Catic Title Insurance Company, Etc. v. Cecere · filed 2024-03-07(a)

We also agree that the action was governed by the twenty-year statute of limitations for real estate actions, pursuant to N.J.S.A. 2A:14-7, rather than the six-year limitations period for contractual claims under N.J.S.A. 2A:14-1(a), because the underlying action related to the priority of mortgage liens attached to real estate.

Section 2A:14-1 provides a six-year limitations period for fraud and New Jersey Consumer Fraud Act claims.

NORTON v. MYLAN INC. · filed 2024-04-02

Under New Jersey law, the statute of limitations for fraud is six years, see N.J. Stat. Ann. § 2A:14-1, and a cause of action accrues when a plaintiff knows or should know of its existence.

Section 2A:14-1 imposes a six-year limitations period on contractual claims and liabilities not under seal.

Bank of America, N.A. v. Maher · filed 2024-04-12(a)

The six-year limitations period set forth in N.J.S.A. 2A:14-1 applies "for recovery upon a contractual claim or liability, expressed or implied, not under seal, or upon an account other than one which concerns the trade or merchandise between merchant and merchant, their factors, agents, and servants." ... Instead, the six-year limitations period under N.J.S.A. 2A:14-1(a) governs the present dispute. ... When an acceleration clause is activated, a cause of action occurs ... when payment is not made because the debt becomes immediately due and payable. Therefore, once the debt is accelerated, N.J.S.A. 2A:14-1(a) provides a six-year SOL. ... The six-year SOL therefore ran from the acceleration date.

Section 2A:14-1 imposes a six-year limitations period on tortious-interference claims under New Jersey law.

SHAIKH v. STATE OF NEW JERSEY - DEPARTMENT OF BANKING & INSURANCE, DIVISION OF INSURANCE · filed 2024-04-30

Finally, because the statute of limitations for claims of tortious interference under New Jersey law is six years, Shaikh had until approximately June 2022 to file his claims for tortious interference against the Attorney Defendants.

Section 2A:14-1 provides a six-year statute of limitations for tortious interference and breach-of-contract claims in New Jersey.

HP HOLDING LLC v. RED ROOF INNS, INC. · filed 2024-05-28

Under New Jersey law, the statute of limitations for tortious interference is six years. N.J. Stat. Ann. § 2A:14-1; see also Devine v. LyondellBasell Indus., N.V., Civ. No. 15-8406, 2016 WL 5934705, at *3 (D.N.J. Oct. 12, 2016).

Section 2A:14-1 imposes a six-year limitations period on breach of fiduciary duty and personal property conversion claims.

LETTIERI v. TD BANK · filed 2024-06-21

Importantly, a claim for breach of fiduciary duty is subject to a six-year statute of limitations, meaning the claim must be asserted within six years after its accrual. N.J. Stat. Ann. § 2A:14-1; see also Acquaviva v. Est. of DiMisa, 2012 WL 4935276, at *5 (N.J. Super. Ct. App. Div. Oct. 18, 2012). ... Plaintiff’s claim that Defendant breached its fiduciary duties is time-barred. ... Like a claim for breach of fiduciary duties, a claim for conversion of personal property is subject to a six-year statute of limitations. N.J. Stat. Ann. § 2A:14-1; see also Dynasty Bldg. Corp. v. Ackerman, 870 A.2d 629, 630 (N.J. Super. Ct. App. Div. 2005). ... Plaintiff did not learn of the alleged conversion until 2023, which is when the limitations period would begin to run. See Acquaviva, 2012 WL 4935276, at *5. Therefore, the Court will allow a claim for conversion to proceed past the screening stage.

Section 2A:14-1 imposes a six-year limitations period on the legal-malpractice claim discussed by the court.

Kamdem-Ouaffo v. Colgate Palmolive Co · filed 2024-07-01

To the extent that Kamdem-Ouaffo was attempting to present new claims related to legal malpractice, these claims were untimely, as the New Jersey statute of limitations for such a claim is six years, see N.J. Stat. Ann. § 2A:14-1, and the alleged conduct occurred over seven years prior to the commencement of the instant proceedings. Consequently, the District Court dismissed these claims as well. ... Upon review, we agree with the District Court’s reasoning and conclusions regarding the dismissal of Kamdem-Ouaffo’s claims.

Section 2A:14-1 provides a six-year limitations period for insurance contract claims, but the period may be shortened by the insurance contract.

Gutierrez v. American Bankers Insurance Company of Florida · filed 2024-07-17

The question is whether the insurer could shorten a statutory limitations period for the filing of an action against it, and whether plaintiff was apprised of that amendment. The answer is yes. ... We noted that, under New Jersey law, there is a six-year statute of limitations for claims brought pursuant to an insurance contract. Ibid. (citing, among others N.J.S.A. 2A:14-1(2022)). "However, that period may be shortened by the terms of an insurance contract." Ibid.

Section 2A:14-1 sets a six-year limitations period for the listed contract and related claims.

AZOG, INC. v. GOLDEN INTERGRITY, INC · filed 2024-08-05

Likewise, under N.J.S.A. § 2A:14-1, there is a six-year limit for Plaintiffs’ six claims for breach of contract (Count 4); breach of fiduciary duty/duty of loyalty (Count 8); breach of implied covenant of good faith and fair dealing (Count 9); Loss of income (Count 11); and interference with contract (Count 12). ... Accordingly, all of the remaining claims would be barred under the relevant statutes of limitations. Under these circumstances, the Court concludes that it would be futile to permit further amendment to the Complaint in this matter.

Section 2A:14-1 requires actions for tortious injury to another's rights to be commenced within six years after the cause of action accrues.

COSTAMAR TRAVEL CRUISE & TOURS, INC. v. PENA · filed 2024-10-04

The Court will also not grant default judgment on Count IV under the New Jersey unfair competition statute, N.J.S.A. 56:4-1, and Count V under New Jersey common law, as these Counts are interpreted by courts to be subject to the New Jersey six-year statute of limitations for tortious injury to the rights of another. N.J.S.A. § 2A:14-1 (“Every action at law . . . for any tortious injury to the rights of another not stated in N.J.S.2A:14-2 and N.J.S.2A:14-3 .. . shall be commenced within six years next after the cause of any such action shall have accrued.”)

Section 2A:14-1 gives six years to bring claims for breach of fiduciary duty and fraud causing purely economic loss, measured from the act or omission or when it should reasonably have been discovered.

Joan Geswaldo, Etc. v. Geswaldo · filed 2024-10-30

The judge found Christine and Rachel's claims for breach of fiduciary duty and fraud resulting in purely economic loss were subject to the six-year statute of limitations in N.J.S.A. 2A:14-1, and those claims accrued on the date of the act or omission giving rise to the claim or when such should have been reasonably discovered. ... That finding, based on Christine's and Rachel's admissions at trial and the K-1 forms, is sound — and dispositive of defendants' appeal of the dismissal of their counterclaims.

Section 2A:14-1 gives a claimant six years to bring a claim for breach of a mortgage.

Ditech Holding Corporation · filed 2025-02-08

Here, Claimant has alleged breach of the mortgages, which is subject to the six-year statute of limitations under section 2A:14-1.

Section 2A:14-1 requires claims for tortious injury, conversion, and express or implied contracts to be filed within six years after they accrue.

Russack v. Rosenberg · filed 2025-04-15

Plaintiffs filed their complaint six years, one month, and twenty-five days after the closing date and one year, nine months, and two days after Levitin purportedly gave Ira the closing documents, placing the filing of the complaint, considering only those dates, beyond the longest applicable statute of limitations. See, e.g., N.J.S.A. 2A:14-1 (requiring actions for tortious injury, conversion, or express or implied contractual claims to "be commenced within six years next after the cause of any such action shall have accrued").

Section 2A:14-1 imposes a six-year limitations period for legal malpractice claims, subject to accrual under the discovery rule.

Merlin's Kids, Inc. v. Pc · filed 2025-05-05

A claim of legal malpractice is subject to a six-year statute of limitations. McGrogan v. Till, 167 N.J. 414, 419 (2001) (citing numerous cases applying N.J.S.A. 2A:14-1). "Ordinarily, a cause of action 'accrues when an attorney's breach of [his or her] professional duty proximately causes a plaintiff's damages.'" ... In this matter, plaintiffs' legal malpractice action accrued in March 2014. Moreover, under the discovery rule, plaintiffs were aware of defendant's alleged breach of professional duty and the potential for damages in March 2014. ... Because plaintiffs waited until August 2023 to sue defendant, the six-year statute of limitations had already run, and their claim was time-barred.

Section 2A:14-1(a) provides a six-year limitations period for contractual claims, subject to a shorter period agreed to in an insurance policy.

Vanrell v. United Services Automobile Association · filed 2025-08-06(a)

Thus, State law provides the statutory limitations period applies, unless the parties agree to a different limitations period in their insurance policy. The four-year/one-year limitation period in the policy, therefore, is not in conflict with State law.

Section 2A:14-1 requires covered contractual and quasi-contract claims to be commenced within six years after accrual.

Supor Properties Enterprises LLC · filed 2025-09-08

New Jersey Statute Annotated 2A:14-1 provides that every action at law for recovery upon a contractual claim or liability, express or implied, “shall be commenced within 6 years next after the cause of any such action shall have accrued.” As the Court will discuss, the same statute of limitations applies to Bezzone’s alternate claims of quantum meruit and unjust enrichment. See N.J.S.A. 2A:14-1. To determine when a cause of action accrued, the relevant inquiry is when did the party seeking to bring the action have an enforceable right.

The section gives fraud, conversion, breach of contract, and civil conspiracy claims a six-year filing period.

PATEL v. AP HOSPITALITY, LLC · filed 2025-09-22

The claims for fraud, conversion, breach of contract, and civil conspiracy are all governed by a six-year statute of limitations. N.J.S.A. 2A:14-1; see Kretz v. Hernandez, No. 3:12-CV-03152, 2016 WL 6471444, at *3 (D.N.J. Oct. 31, 2016).5 Summary Judgment must be granted if these claims are found to be untimely. ... Because of this, plaintiff’s claims arising from the transaction to acquire a membership interest in AP Hospitality accrued in 2008, fourteen years before the filing of this action. This is beyond the applicable six-year statute of limitations for their claims and they must be dismissed.

Section 2A:14-1(a) requires contract actions to be commenced within six years after accrual and prevents laches from barring an action filed within that period.

Route 22 Nissan, Inc. v. European Auto Expo, LLC · filed 2025-09-24(a)

However, the doctrine of laches is only appropriate "in the absence of the statute of limitations." Fox, 210 N.J. at 418. Where an action at law is governed by a statute of limitations, the equitable doctrine of laches cannot apply to bar a suit commenced within the limitations period. Id. at 419-20. Under N.J.S.A. 2A:14-1(a), "[e]very action at law . . . for recovery upon a contractual claim or liability . . . shall be commenced within six years next after the cause of any such action shall have accrued.

Section 2A:14-1 provides a six-year limitations period that can bar fraud-related claims, subject to the discovery rule.

Singletary v. Equity Source Home Loans, LLC · filed 2024-02-21

Plaintiffs’ fraud-related claims, Counts One through Five, could be barred by the six-year statute of limitations. See N.J.S.A. 2A:14-1, et seq; see also Wells Fargo Bank, NA v. Taylor, 2020 WL 1291450 (N.J. Super. App. Div. Mar. 18, 2020) (barring, pursuant to N.J.S.A. 2A:14-1, mortgagor’s fraud-based claims against bank after foreclosure action under six-year statute of limitations, when mortgagor executed the note in 2010 and raised untimely fraud allegations in 2017). ... To address the question of whether Plaintiffs’ statute of limitations is tolled by the discovery rule, this Court will hold a “Lopez hearing” to determine when Plaintiffs learned, or reasonably should have learned, that fraud occurred. Under New Jersey law, whether a claim is barred by the statute of limitations is a question of law, and application of the discovery rule is for the court to decide through a preliminary hearing. Lopez, 62 N.J. at 275. The Lopez court held that a preliminary hearing outside of the jury’s presence was necessary when assessing whether the plaintiff could benefit from the discovery rule. The Plaintiffs have the burden of proving whether they are equitably entitled to the discovery rule’s benefit. Id.

Section 2A:14-1(a) gives a claimant six years from accrual to sue for tortious injury to another's rights; the claim against this arbitrator accrued when she issued her written final disposition.

Thorpe v. Rosemarie Cipparulo, Esq. · filed 2025-10-24(a)

Additionally, plaintiff had six years to file this cause of action against Klein but did not. Pursuant to N.J.S.A. 2A:14-1(a), "[e]very action at law . . . for any tortious injury to the rights of another not stated in N.J.S.A. 2A:14-2 and N.J.S.A. 2A:14-3 . . . shall be commenced within six years next after the cause of any such action shall have accrued." Klein's written opinion with her final disposition was issued February 12, 2010, making that date the date of accrual. Appellant filed this claim on July 19, 2022. Consequently, this cause of action was filed far outside of the six-year statute of limitations.

Section 2A:14-1(a) provides a six-year limitations period for RISA, TCCWNA, and CFA claims.

Morrell v. Retrofitness, LLC · filed 2026-01-20(a)

The statute of limitations for a RISA claim, a TCCWNA claim, and a CFA claim is six years.

Section 2A:14-1 sets a six-year limitations period for replevin and contractual claims.

Oliver v. Short v. Steven M. Resnick · filed 2026-02-05(a)

N.J.S.A. 2A:14-1 sets a six-year statute of limitations "for replevin of goods or chattel" and "for and recovery upon a contractual claim or liability, express or implied." ... The statute of limitations for plaintiff's replevin claim based on the 2015 consent order ran in 2021. Thus, his claim is time-barred.

Section 2A:14-1 provides a six-year limitations period for a malicious abuse of process claim.

Owens v. Robertson Anschutz Schneid Crane & Partners PLLC · filed 2026-05-29

Those actions, which allegedly included filing false and forged pleadings, were taken after the matter was remanded from the Superior Court in 2020, and thus the claim was timely filed within the six-year statute of limitations. See N.J. Stat. Ann. § 2A:14–1.

Section 2A:14-1 sets a six-year limitations period for contract claims and does not create a private cause of action.

ALLEN · filed 2026-02-09

As both provisions are statutes of limitations, they do not provide Ms. Allen with a private cause of action but rather govern the timeliness of her alluded to breach of contract claim.

Section 2A:14-1 supplied the six-year limitations period previously applied to Section 14(a) proxy claims, measured here from discovery of the misleading statement.

Westinghouse Elec. Corp. by Levit v. Franklin · filed 1992-04-21

In Roberts v. Magnetic Metals Co., 611 F.2d 450 (3d Cir.1979), the Third Circuit applied the New Jersey six-year statute of limitations governing actions for common-law fraud, N.J.S.A. 2A:14-1, to a Section 14(a) claim. Accord Biggans v. Bache Halsey Stuart Shields, 638 F.2d 605, 610 (3d Cir.1980). Since plaintiffs filed their cause of action within six years of discovering the misleading Proxy Statement, see Aykan v. Goldzweig, 238 N.J.Super. 389, 569 A.2d 905 (Law Div.1989), the new statute of limitation will not bar their suit.

Section 2A:14-1 sets a six-year limitations period for conversion claims.

Arcand v. Brother International Corp. · filed 2009-11-30

BIC again argues that a conflict exists between New Jersey and Virginia conversion laws because of the shorter statute of limitations in Virginia, five-years, versus the six-year limitation in New Jersey. Va.Code § 8.01-243(B); N.J.S.A. § 2A:14-1. However, Arcand’s claim is well-within both statutes of limitation, and as already discussed above, no actual conflict exists. The Court finds because no conflict exists between New Jersey and Virginia conversion laws, New Jersey law applies.

Section 2A:14-1 provides a six-year limitations period for New Jersey property damage claims.

Harleysville Preferred Insurance Company v. Dude Products, Inc. · filed 2022-12-21

Yet because the plaintiffs propose a "Multi-State Subclass" that includes residents of Minnesota and New Jersey, id. ¶ 38, Dude Product argues that the suit potentially alleges property damage claims within the policy period because Minnesota and New Jersey have six-year statutes of limitations for such claims. See Minn. Stat. § 541.05; N.J. Stat. § 2A:14-1. ... Because the allegations of clogging or other sewer damage could similarly be read as an attempt to recover for physical damage to the plaintiffs' plumbing and other property, the underlying complaint provides a potential for Minnesota and New Jersey property damage claims arising out of conduct within the policy's coverage period.

Section 2A:14-1 provides a six-year limitations period for professional malpractice claims.

Abramo v. Teal, Becker & Chiaramonte, CPA's, P.C. · filed 2010-05-12

This three-year period is shorter than the six years provided for under New Jersey law.

Section 2A:14-1 provides a six-year limitations period for strict liability and negligence claims that begins when the plaintiff discovers the injury.

ICI Australia Ltd. v. Elliott Overseas Co. · filed 1982-10-28

On the other hand, an action based on strict liability or negligence is governed by New Jersey’s general statute of limitations, N.J.S.A. 2A:14-1. This statute gives a six-year limitations period which does not begin to run until the plaintiff discovers his injury.

Section 2A:14-1 bars a claim for injury to real property filed more than six years after it accrued.

Atkinson v. Pittsgrove Tp. · filed 1983-11-09

It is clearly barred by the statute of limitations, N.J.S.A. 2A:14-1 (six years for injury to real property), for even under plaintiff's erroneous view that the injury to his land accrued in 1973, ten years have elapsed since that date.

Section 2A:14-1's six-year limitations period applies to a buyer's strict liability tort claim for economic loss caused by defective goods.

Spring Motors Distributors v. Ford Motor Co. · filed 1983-08-29

Since a strict liability claim rests not on any contractual basis but upon a breach of duty owed generally to the consumers of a product, Rosenau v. City of New Brunswick and Gamon Meter Co., supra, 51 N.J. at 143-144, and considering the Supreme Court's opinion in Heavner, we conclude that N.J.S.A. 12A:2-725 does not apply and that the six-year limitation period provided by N.J.S.A. 2A:14-1 for property damages applies.

Section 2A:14-1 gives plaintiffs six years from accrual to bring strict liability and nuisance claims.

Analytical Measurements, Inc. v. Keuffel & Esser Co. · filed 1993-10-28

The limitation periods applicable to plaintiffs’ strict liability and nuisance claims are governed by N.J.Stat.Ann. § 2A:14-1, which requires that such actions be brought within six years of when the cause of action accrued.

Trade libel claims fall under the six-year limitations period for tortious injury to property or rights.

Patel v. Soriano · filed 2004-05-18

Although we need not address the issues of waiver, equitable tolling, fraudulent concealment or relation back as we now conclude that plaintiff did set forth a cause of action for trade libel that was not barred by the one-year limitation period, we first set forth the relevant statute and then recount the procedural background of this litigation to put our determination in context. ... However, N.J.S.A. 2A:14-1 also provides: Every action at law ... for any tortious injury to real or personal property, for taking, detaining, or converting personal property, ... [or] for any tortious injury to the rights of another not stated in sections 2A:14-2 and 2A:14-3 of this Title,... shall be commenced within 6 years next after the cause of any such action shall have accrued.

Section 2A:14-1 provides a six-year limitations period for common law claims involving the taking, detaining, or converting of personal property.

Lee v. First Union Nat. Bank · filed 2008-08-27

Even if Evergreen Omega was not so exempt, the gravamen of this count of the complaint concerns the unlawful "taking, detaining, or converting" of personal property, which is subject to the six-year statute of limitations of N.J.S.A. 2A:14-1.

Section 2A:14-1 gives a property owner six years to bring a claim for permanent loss of property value, measured from when the owner discovers the injury.

320 ASSOCIATES, LLC VS. NEW JERSEY NATURAL GAS CO. (L-1180-16, OCEAN COUNTY AND STATEWIDE) · filed 2018-06-29

In this case, the parties agree that the applicable statute of limitations (SOL) is the six-year SOL for tortious injury to real property. N.J.S.A. 2A:14-1. ... Thus, the six-year statute of limitations for a damages claim based on permanent diminution in the value of the property began to run in 2008 and expired in 2014.

Section 2A:14-1 requires an estate to bring a property trespass claim within six years of the event; the Survivor Act does not extend that period.

Warren v. Muenzen · filed 2016-12-07

For example, if a decedent's property was flooded by his neighbor's diversion of storm water, pursuant to N.J.S.A. 2A:14-1, his estate would be required to file suit for trespass within six years of the event.

Section 2A:14-1's six-year limitations period applies to commercial disparagement claims.

Fairfax Financial Holdings Limited v. S.A.C. · filed 2017-04-27

The six-year statute of limitations applies to plaintiffs' disparagement claims, as well as their other common law causes of action.

Section 2A:14-1 gives a plaintiff six years to bring a conversion claim in New Jersey.

White v. US Bank · filed 2017-08-10

We detect no error in the District Court’s treatment of White’s claim as “one of conversion,” and agree that it is time-barred by the six-year statutes of limitations that govern such claims in both New Jersey and Minnesota. See N.J. Stat. 2A:14-1; Minn. Stat. § 541.05(4).

The six-year period for bringing a replevin action can bar an owner who knows another person possesses the property from later claiming ownership.

IN THE MATTER OF OWNERSHIP OF 1969 CHEVROLET CORVETTE (L-2110-16, OCEAN COUNTY AND STATEWIDE) · filed 2018-07-18

Stated differently, was Black barred from claiming an ownership interest in the car at a point in time beyond the six-year statute of limitations to commence an action for replevin? See N.J.S.A. 2A:14-1. ... Based on his factual findings, Judge Brenner properly applied the Court's holding in O'Keeffe to conclude Biaza had legal title of the 1969 Corvette at the time he sold it to Roth.

Section 2A:14-1 provides a six-year limitations period for inverse condemnation actions in New Jersey.

287 Corp Ctr Assoc v. Bridgewater Twp. · filed 1996-11-27

But in New Jersey, the most analogous state statute provides a six year limitations period. See N.J. Stat. Ann. § 2A:14-1. Although the statute does not explicitly reference inverse condemnation actions, New Jersey decisional law indicates it is the proper statute of limitations in such cases.

Section 2A:14-1 provides a six-year limitations period for inverse condemnation actions under New Jersey law.

287 Corporate Center Associates v. The Township of Bridgewater, a Municipal Corporation of the State of New Jersey · filed 1996-11-27

But in New Jersey, the most analogous state statute provides a six year limitations period. ... Although the statute does not explicitly reference inverse condemnation actions, New Jersey decisional law indicates it is the proper statute of limitations in such cases.

Section 2A:14-1 gives six years to bring a claim for tortious injury to real or personal property.

Jonas v. Gold · filed 2015-09-23

The statute of limitations for tortious injury to real or personal property is six years. N.J. Stat. Ann. § 2A: 14-1. ... Edwin’s claims are all time-barred.

Section 2A:14-1 requires a claim for tortious injury to real property to be filed within six years of accrual; the claim accrues when the alleged negligent act occurs.

GOEL VS. NEW JERSEY DEPARTMENT OF CORRECTIONS (NEW JERSEY DEPARTMENT OF CORRECTIONS) · filed 2017-06-29

A claim for tortious injury to real property must be filed within six years after the cause of action has accrued. N.J.S.A. 2A:14—1. Although plaintiffs claim that due to the negligence of defendant's employees, the house sustained damage in 2009 and 2011, the cause of action accrued at the time of the alleged negligent act, which plaintiffs claim occurred on February 9, 2009. The trial court correctly found that the negligence claim was not timely filed.

Section 2A:14-1 gives a plaintiff six years to bring a claim for damage to property.

SHAIR VS. MASARU TSUBOI AND TOKIKO TSUBOI(L-0173-16, BERGEN COUNTY AND STATEWIDE) · filed 2017-11-14

We affirm substantially for the reasons stated by Judge Rachelle L. Harz in her opinion placed on the record on April 18, 2015. ... There is a six-year statute of limitations of this type of cause of action. N.J.S.A. 2A:14-1.

The six-year limitations period for tortious injury to property does not save claims filed after that period when the discovery rule does not apply.

Levine v. New Jersey State Department of Community Affairs · filed 2007-04-10

Accordingly, because we do not believe that the discovery rule is applicable, Levine’s argument that New Jersey’s 6-year statute of limitations (presumably under N.J.S.A. 2A:14-1 for tortious injury to property) should apply does not help him here, either. Assuming he had provided a federal claim “of sufficient substance” such that a federal court could exercise pendant jurisdiction over state law claims, those claims would nonetheless be time barred under state law.

The six-year limitations period for an inverse condemnation claim runs from the State actions giving rise to the claim.

STAVROS, INC. VS. STATE OF NEW JERSEY, ETC. VS. SOUTH STATE, INC. (L-2788-13, BURLINGTON COUNTY AND STATEWIDE) · filed 2019-09-12

The DOT also argues in its reply brief that Stavros's inverse taking claim is time-barred under the six-year statute of limitations, N.J.S.A. 2A:14-1, because the DOT's final agency decision letter was dated February 21, 2006, and Stavros did not file its inverse affirmative pleading until March 22, 2013. As the trial court noted, Stavros's claim concerns State actions beginning in 2009. Thus, Stavros's claim is not time-barred.

The six-year limitations period bars an insurer’s claim for indemnification and defense costs filed more than six years after it became obligated to pay a settlement.

ACE AMERICAN INSURANCE COMPANY VS. OLD REPUBLIC GENERAL INSURANCE CORP. (L-1801-18, BERGEN COUNTY AND STATEWIDE) · filed 2020-01-03

Therefore, ACE's March 12, 2018 declaratory judgment action was barred by the six-year statute of limitations.

The six-year limitations period for tortious interference and abuse of process claims is not extended by the continuing tort doctrine when the alleged wrongdoing consists of discrete lawsuits.

EGG HARBOR ASSOCIATES, LLC VS. VILLAGE SUPERMARKETS, INC. (L-0438-18, ATLANTIC COUNTY AND STATEWIDE) · filed 2020-01-13

Plaintiff's tortious interference and abuse of process claims fall outside the scope of the narrowly delineated contexts in which the continuing tort doctrine has been recognized.

Section 2A:14-1’s six-year period bars a wrongful-occupancy claim filed more than six years after the claimant became a co-administrator, even assuming the claim accrued upon appointment.

IN THE MATTER OF THE ESTATE OF FAITH HURSA (P-000091-16, BERGEN COUNTY AND STATEWIDE) · filed 2020-02-26

Amy argues, and we agree, that plaintiff's claims are barred because plaintiff became an administrator in 2009 and did not file her complaint until 2016, thus exceeding the six-year statute of limitations.

Section 2A:14-1 bars a replevin counterclaim filed after the six-year limitations period expires.

HERB PETERMANN VS. MARIA G. DUARTE (C-000185-16, BERGEN COUNTY AND STATEWIDE) · filed 2019-04-08

Because more than six years expired, this counterclaim was barred by N.J.S.A. 2A:14-1.

A construction-defect action must be filed within six years after the claim accrues.

RIVA POINTE AT LINCOLN HARBOR CONDOMINIUM ASSOCIATION, INC VS. TISHMAN CONSTRUCTION CORPORATION (L-4104-15, HUDSON COUNT · filed 2020-06-15

Under N.J.S.A. 2A:14-1, a construction-defect action must be commenced within six years "after the cause of any such action shall have accrued."

Section 2A:14-1 allows six years after accrual to bring a New Jersey action for conversion of personal property.

Dolores G. Williams · filed 2021-05-12

Thus, the trustee is not time-barred from bringing a state law action in connection with the prepetition transfers.

Section 2A:14-1 gives an owner six years to bring a replevin action, starting when the possessor's possession has the elements of adverse possession.

O'KEEFFE v. Snyder · filed 1979-07-27

In direct answer to the questions posed at the outset of this opinion, a cause of action for replevin accrues, in the sense that the statutory time in which suit must be brought starts runnings, when the possession by the defendant, or by those claiming through him, assumes the characteristic elements of adverse possession.

The six-year period for an action involving the taking, detention, or conversion of personal property may be subject to the discovery rule when the claimant did not know the error or the recipient's identity.

Federal Insurance Co. v. Hausler · filed 1970-01-29

N.J.S.A. 2A:14-1 requires that an action at law for taking, detaining or converting personal property be commenced within six years after such action shall have accrued. ... We see no reason why the present situation is not one appropriate for a further extension of the rule. ... The matter should have been fully tried to determine (1) whether Walker knew or reasonably should have known of the error and defendants' identity in December 1961 and, if not, whether the discovery of defendants' identity in November 1962 was within a reasonable time; and (2) whether defendants knew of the mistake from the very beginning and therefore fraudulently concealed their windfall.

Section 2A:14-1’s six-year period for replevin of a painting begins when the owner knew or reasonably should have known, through due diligence, of the claim and the possessor’s identity.

O'KEEFFE v. Snyder · filed 1980-07-17

Similarly, we conclude that the discovery rule applies to an action for replevin of a painting under N.J.S.A. 2A:14-1. O'Keeffe's cause of action accrued when she first knew, or reasonably should have known through the exercise of due diligence, of the cause of action, including the identity of the possessor of the paintings.

The six-year period for property tort claims is subject to the discovery rule; when that rule applies, the court asks when the plaintiff knew of the injury and that another party was at fault.

Amland Properties Corp. v. Aluminum Co. of America · filed 1992-12-22

Thus, in applying the discovery rule to Amland’s claims, it must be determined whether Amland knew of its injury and knew that the injury was the fault of another prior to December 2, 1985.

The six-year period for a tort claim begins when the plaintiff knows of its injury and the responsible party; a later refusal to pay additional compensation does not delay it.

PT & L. CONST. v. Madigan & Hyland · filed 1991-01-10

Consequently, P.T. & L.'s assertion that the statute began to run in 1977 after the DOT refused to grant it additional monies is not viable. This suit is therefore barred by the six-year statute of limitations and the damage award was improper.

Section 2A:14-1’s six-year limitations period does not bar a strict liability claim based on an abatable continuing tort because a new limitations period begins each day the harmful condition remains.

Interfaith Community Organization v. Honeywell International, Inc. · filed 2003-05-21

The Court concludes that the “abnormally dangerous” activities attributable to Honeywell at the ECARG Property constitute “continuing torts,” and therefore that ECARG’s strict liability claim is not barred by the six-year statute of limitations, N.J. Stat. Ann. § 2A:14-1, as Honeywell contends.

Section 2A:14-1 provides a six-year limitations period for replevin actions.

Lakeland Bank v. Sun-Re Cheese Corp. · filed 2023-02-21

We hold that the New Jersey statute of limitations for replevin of six years applies to this case and the case was timely filed.

Section 2A:14-1 provides a six-year limitations period for trespass claims.

TAYLOR-MARSHALL v. CITY OF NEW BRUNSWICK · filed 2023-07-31

Because the conduct forming the basis for Plaintiff's Complaint occurred in October 2002 (see ECF No. 4 at 8-9), the statute of limitations for Plaintiff's trespass claim expired in or around October 2008.

Section 2A:14-1 gives malicious prosecution claims a six-year limitations period as claims for tortious injury to another's rights.

Sexton v. State of New Jersey · filed 2026-01-29

Unlike CRA and LAD claims, malicious prosecution claims are governed by the six-year statute of limitations for "tortious injury to the rights of another." N.J.S.A. 2A:14-1.

Section 2A:14-1’s six-year limitations period bars state-law fraud claims when plaintiffs knew or reasonably should have known of the alleged fraud more than six years before filing suit.

Osadchy v. Gans · filed 1977-07-20

The State causes of action raised in diversity are likewise barred by the six-year statute of limitations.

Section 2A:14-1 gives six years to bring New Jersey claims for negligent misrepresentation, fraud or deceit, and breach of fiduciary duty; the period begins when the injured party discovers or should discover the injury.

Kronfeld v. First Jersey National Bank · filed 1986-06-20

The statute of limitations governing actions for negligent misrepresentation, fraud or deceit, and breach of fiduciary duty under New Jersey law is N.J.S.A. 2A:14-1, which provides in relevant part, “Every action at law ... for any tortious injury to the rights of another ... shall be commenced within 6 years next after the cause of any such action shall have accrued.” An action accrues under this section when a party discovers or should discover the injury.

Section 2A:14-1 provides a six-year limitations period for fraud claims.

Francesconi v. Kardon Chevrolet, Inc. · filed 1988-12-27

The New Jersey statute of limitations for fraud is six years. N.J.Stat.Ann. § 2A:14-1 (West 1987); ... Since plaintiffs cause of action accrued on October 10, 1985, he is not barred from bringing his Consumer Fraud Act claim in state court.

Section 2A:14-1 gives a fraud claim six years from accrual; an amendment asserting fraud after that period is untimely.

Hartford Accident and Indemnity Co. v. Baker · filed 1985-11-01

The relevant statute in New Jersey's statute of limitations for fraud is six years after any such action has accrued. N.J.S.A. 2A:14-1. ... Under the New Jersey statute addressing fraud, the proposed amendment would be out of time.

Section 2A:14-1 gives a plaintiff six years from accrual to bring a fraud action under New Jersey law.

Zola v. Gordon · filed 1988-05-04

Under New Jersey law, actions for fraud must be commenced “within 6 years next after the cause of any such action shall have accrued.” N.J. Stat. Ann. § 2A:14-1 (West 1987).

The six-year limitations period applies to common-law fraud and Consumer Fraud Act claims arising from a sales transaction.

D'ANGELO v. Miller Yacht Sales · filed 1993-02-05

An express provision of the Code, N.J.S.A. 12A:1-103, saves from preemption common-law fraud and Consumer Fraud Act claims arising from a sales transaction. Such claims may be brought within six years of accrual.

Section 2A:14-1 provides a six-year limitations period for fraud claims, measured from accrual.

Delgozzo v. Kenny · filed 1993-07-20

If a fraud claim is asserted, the appropriate limitation would be six years from the accrual of the claim. N.J.S.A. 2A:14-1; D'Angelo v. Miller Yacht Sales, supra, 261 N.J. Super. at 688, 619 A. 2d 689.

Section 2A:14-1 provides a six-year limitations period for fraud claims under New Jersey law.

Concern Sojuzvneshtrans v. Buyanovski · filed 1999-08-31

In contrast, the applicable statute of limitation in New Jersey is six years. See N.J.S.A. 2A:14-1.

Section 2A:14-1 provides a six-year limitations period for common-law fraud claims.

Voilas v. General Motors Corp. · filed 1997-05-09

However, this Court finds that the relevant statute of limitations for plaintiffs’ common law fraud claims is six years, and therefore plaintiffs’ claims are not time-barred.

The six-year limitations period for a fraud claim begins when the plaintiff knew or should have known facts that would lead a reasonable person to question the alleged misrepresentation.

Southern Cross Overseas Agencies, Inc. v. Wah Kwong Shipping Group Ltd. · filed 1999-06-25

Thus, the limitations period did not start to run when the plaintiffs knew or should have known that Wah Kwong represented itself as a creditor. Rather, the period would begin to run only when they knew or should have known information that would have led a reasonable person to question that representation.