N.J. Stat. Ann. § 2A:14-1

The six-year period for a fraud claim begins when the plaintiff suffers actual damage; advance notice of a future termination does not start the period.

Holmin v. TRW, INC. · filed 2000-04-07

Such damage is essential to a fraud claim, and thus plaintiff's cause of action did not accrue until March 13, 1992. Accordingly, the six year limitation period respecting his suit also began on March 13, 1992, it expired on March 12, 1998, and thus his March 11, 1998 complaint was timely.

Section 2A:14-1 provides a six-year limitations period for Consumer Fraud Act claims, with a concealed fraud claim accruing when the plaintiff discovers or reasonably should discover the wrong.

NN&R, Inc. v. One Beacon Insurance Group · filed 2005-03-15

A claim under the Consumer Fraud Act is governed by a six year statute of limitations. ... Accordingly, Plaintiffs Consumer Fraud Act claim is not barred by the applicable statute of limitations.

Section 2A:14-1 gives fraud claims a six-year limitations period that begins when the plaintiff knows or should know of the claim.

Gillespie v. Janey · filed 2011-08-16

Under New Jersey law, fraud claims are subject to a six-year statute of limitations, see N.J. Stat. Ann. § 2A:14-1, S. Cross Overseas Agencies, Inc. v. Wah Kwong Shipping Group, 181 F.3d 410, 425 (3d Cir. 1999), “and a cause of action accrues when a plaintiff ... knows or should know of its existence.” Id.

Section 2A:14-1 gives fraud and negligent misrepresentation claims a six-year limitations period.

Rapid Models & Prototypes, Inc. v. Innovated Solutions · filed 2014-12-29

In New Jersey, a six-year statute of limitations applies to fraud claims. ... New Jersey applies a six-year statute of limitations to negligent misrepresentation claims.

Section 2A:14-1 gives New Jersey Consumer Fraud Act claims a six-year limitations period that runs from the later of the alleged fraud or when reasonable diligence could have uncovered it.

Rodrigues v. Wells Fargo Bank NA · filed 2018-09-26

Rodrigues’s claim under the New Jersey Consumer Fraud Act is subject to a six- year statute of limitations. N.J.S.A. 2A:14-1. That limitations period runs from the later of the time the alleged fraud occurred or the time it could have been discovered with reasonable diligence.

Section 2A:14-1 gives a fraud claim six years from accrual, subject to equitable tolling under the discovery rule.

BENIPAL VS. TRI-STATE PETRO, INC. (C-000060-17, MERCER COUNTY AND STATEWIDE) · filed 2019-01-04

Here, when plaintiffs filed their complaint in July 2017, both causes of action would have been time-barred, unless the statutes of limitations were equitably tolled by the discovery rule. ... Further, pursuant to N.J.S.A. 2A:14-1, a fraud claim must be commenced within six years after the cause of action accrues.

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

Kennedy-Jarvis v. Wells · filed 2016-07-01

Those claims, accordingly, are untimely absent the operation of some rule or equitable principle that would delay or toll the statute of limitations.

Section 2A:14-1 gives fraud and breach of contract claims a six-year limitations period.

Lunn v. Prudential Insurance Co. of America · filed 2008-06-30

The statutes of limitations for fraud and breach of contract claims (the only claims Lunn expressly asserted in his appellate brief)2 are six years under both New Jersey law, see N.J. Stat. Ann. § 2A:14-1; ... Lunn’s claim accrued in 1986 when he turned sixty and the Waiver expired. Lunn’s complaint was not filed until 2004, eighteen years later. Obviously, the statute of limitations had expired.

Section 2A:14-1 applies a six-year limitations period to Consumer Fraud Act claims.

CARRINGTON MORTGAGE SERVICES, LLC VS. MIKE CRISMALI (F-014309-17, MERCER COUNTY AND STATEWIDE) · filed 2019-07-05

We agree with the trial court that the CFA and TILA claims were barred by the six-year and one-year statutes of limitations, respectively.

The six-year limitations period barred fraud-based claims and defenses asserted more than six years after the note and mortgage were executed.

WELLS FARGO BANK, NA VS. WILLIAM H. TAYLOR (F-014804-17, HUNTERDON COUNTY AND STATEWIDE) · filed 2020-03-18

The six- year statute of limitations expired on March 26, 2016. However, defendant did not assert his fraud-based defenses and claims until August 30, 2017. Therefore, those claims were properly time barred.

Fraud claims have a six-year limitations period that begins when the plaintiff knows or should know of the claim.

KACHUR v. WMC MORTGAGE CORPORATION · filed 2020-07-27

Under New Jersey law, the statute of limitations for fraud is six years, N.J. Stat. Ann. § 2A:14-1, and a cause of action accrues “when a plaintiff knows or should know of its existence,” S. Cross Overseas Agencies, Inc. v. Wah Kwong Shipping Grp. Ltd., 181 F.3d 410, 425 (3d Cir. 1999) (citing Bougher v. Univ. of Pittsburgh, 882 F.2d 74, 80 (3d Cir. 1989)).

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

APPLEBAUM v. FABIAN · filed 2021-12-09

The statute of limitations for fraud is six years, and the allegations of fraud fall within the limitations period. See N.J. Stat. Ann. § 2A:14-1. I therefore consider the merits.

Section 2A:14-1 provides a six-year period to file a fraud or negligent misrepresentation claim.

CASPERSEN v. ORING · filed 2020-02-28

Because this action was filed nineteen months after his discovery of the alleged fraud, it satisfies the limitations requirements imposed by Nevada, New Jersey, and New York law.

Section 2A:14-1 imposes a six-year limitations period on fraud claims arising from loan underwriting.

FARAH v. LASALLE BANK NATIONAL ASSOCIATION · filed 2020-05-18

Second, a fraud claim arising from the underwriting of the 2006 loan (or, for that matter, the 2008 refinancing) would be barred by the six-year statute of limitations. N.J. Stat. Ann. § 2A:14-1.

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

VOORHEES v. TOLIA · filed 2020-03-17

For the fraud claim, there is a conflict of laws, as under Pennsylvania law the statute of limitations is two years from the date of injury, 42 Pa. Con. Stat. § 5524, while the statute of limitations is six years in New Jersey. N.J. Stat. Ann. § 2A:14–1. ... Because the fraud and breach-of-contract actions are alleged to have been conducted by New Jersey entities or citizens, and most are alleged to have been conducted in New Jersey, the Court concludes New Jersey law governs claims related to fraud and breach of contract.

Section 2A:14-1 sets a six-year limitations period for common law fraud, negligent misrepresentation related to property, and Consumer Fraud Act claims.

PASSAIC ARMS CONDOMINIUM ASSOCIATION, INC. VS. FELBEE REALTY, LP (L-2636-11, PASSAIC COUNTY AND STATEWIDE) · filed 2021-12-29

There is a six-year statute of limitations for common law fraud, negligent misrepresentation related to property, and a violation of the CFA.

The six-year limitations period for fraud and Consumer Fraud Act claims begins when the plaintiff discovers, or with reasonable diligence should discover, facts indicating the fraud.

Catena v. Raytheon Company · filed 2016-08-18

In sum, Catena discovered or through reasonable diligence could have discovered the facts giving rise to the fraud claims no earlier than May 21, 2002. Therefore, his claims against Andersen and Wells Fargo, which were filed less than six years after this date, were not time-barred.

For a fraud claim subject to the six-year limitations period, the court must decide whether the discovery rule delays accrual and make credibility findings when necessary.

BERLIN CROSS KEYS SHOPPING CENTER ASSOCIATES, LLC VS. STEPHEN SAMOST, ESQUIRE (L-5114-12, CAMDEN COUNTY AND STATEWIDE) · filed 2019-04-26

This approach was inconsistent with Lopez's mandate that the court make a determination on the discovery rule, and if necessary assess credibility, prior to the case being submitted to the jury for a verdict.

Fraud claims have a six-year limitations period; the discovery rule does not toll that period when a reasonably diligent plaintiff should have discovered the claim earlier.

KIMMERLING VS. ASTORIA BANK (L-1330-17, ATLANTIC COUNTY AND STATEWIDE) · filed 2019-09-17

Under N.J.S.A. 2A:14-1, the statute of limitations for fraud claims is six years. ... The judge appropriately determined that plaintiff, an experienced real estate investor, reasonably should have read the closing documents in 2005 and discovered that the loan term was fifteen years. Accordingly, the judge correctly ruled that plaintiff's claims were not tolled by the discovery rule.

The six-year limitations period may be subject to the discovery rule for a fraudulent misrepresentation claim, so a plaintiff must have an opportunity to amend the complaint to seek its application.

GRACE S. WONG VS. ROBERT G. SCHROEDER (L-5669-18, BERGEN COUNTY AND STATEWIDE) · filed 2019-10-30

Although plaintiff's complaint is premised on Schroeder's breach of contract for failing to pay the notes when they became due, it alleged fraudulent ... misrepresentations, to which the discovery rule could apply. ... Plaintiff should be permitted to amend her complaint and seek application of the discovery rule.

Section 2A:14-1(a) gives a plaintiff six years to bring a Consumer Fraud Act claim, and the discovery rule does not delay accrual when reasonable diligence would have revealed the alleged fraud.

AJAX MORTGAGE LOAN TRUST, ETC. v. KIRK LOURY (F-021065-18, MERCER COUNTY AND STATEWIDE) · filed 2022-07-11(a)

A claim under the CFA "shall be commenced within six years next after the cause of any such action shall have accrued." N.J.S.A. 2A:14-1(a). ... Loury's counterclaim began to accrue when the Note was executed in 2004, because that is when his "exercise of reasonable diligence and intelligence should have discovered" there may be a basis for an actionable claim.

Section 2A:14-1 gives a fraud claimant six years to sue from accrual; the discovery rule may delay accrual until a reasonably diligent person should have discovered a basis for the claim.

BENIPAL v. TRI-STATE PETRO, INC. (C-000060-17, MERCER COUNTY AND STATEWIDE) · filed 2022-08-16

Plaintiffs bore the burden to prove their quiet title action did not accrue until 1997 at the earliest, i.e., within the twenty-year statute of limitations in N.J.S.A. 2A:14-7, and their fraud claim did not accrue until 2011 at the earliest, within the six-year statute of limitations in N.J.S.A. 2A:14-1. They needed to demonstrate that an average investor, even with the exercise of reasonable diligence and intelligence, would not have discovered before 2011 the basis for an actionable claim based on Gill's alleged fraud, or would not have discovered before 1997 that the property was titled in TSP's name.

Section 2A:14-1 gives a plaintiff six years to bring a common law unfair competition claim, and the discovery rule can delay accrual until the plaintiff knew or should have known of the violation.

TALON INDUSTRIES, LLC v. ROLLED METAL PRODUCTS, INC. · filed 2022-08-30

Pursuant to N.J.S.A. § 2A:14-1, a six-year statute of limitations applies to unfair competition claims. ... To toll the statute of limitations for unfair competition claims covered by N.J.S.A § 2A:14-1, a party may avail itself of the discovery rule.

Section 2A:14-1’s six-year limitation does not bar the United States from recovering transportation overcharges under a federal statute.

United States v. Yale Transport Corp. · filed 1960-06-08

There is no substance to the defendant’s contention that, the Government is barred by state statutes of limitation from recovery of overcharges for transportation — claims which rest upon a federal statute.

Section 2A:14-1 applies to a foreign municipality suing in New Jersey as a private suitor.

Buckley v. Huston · filed 1972-05-22

The defendant may of course press any defenses he has on the ultimate merits although we note that his brief before us was confined to the jurisdictional issue which we have rejected and to claims addressed solely to the measure of plaintiff's recovery; these claims were grounded on (1) our statute of limitations ( N.J.S.A. 2A:14-1) and (2) our prevailing doctrine that actions to recover foreign penalties as such are not maintainable. ... In Pennhurst, supra, we pointed out that "when a foreign state sues in the courts of our State it lays aside its sovereignty and is to be dealt with as a private suitor" (42 N.J. at 273); a fortiori a foreign municipality, such as that represented by the plaintiff, is to be dealt with as a private suitor and is subject to the applicable provision in our statute of limitations.

Section 2A:14-1 provides a six-year limitations period for an action against an individual public employee.

Martin v. Tp. of Rochelle Park · filed 1976-09-30

As to the individual defendant Demetrakis, the action, if viable, is governed by the general statute of limitations which allows six years for such suit to be brought. N.J.S.A. 2A:14-1.

Section 2A:14-1's six-year limitation does not apply to an action brought by the State unless the Legislature provides otherwise.

Hyland v. Kirkman · filed 1978-03-10

But more important, the statute of limitations is not applicable to the State unless the Legislature has so provided. ... The argument for dismissal based on N.J.S.A. 2A:14-1 cannot be sustained.

Section 2A:14-1's six-year limitation does not apply to a claim based on statute as it would to an ordinary contract or common law claim.

MC SHAIN v. Township of Evesham · filed 1978-10-31

Plaintiffs' claim here is based upon statute; the limitations of N.J.S.A. 2A:14-1 do not apply as they would to ordinary contract or common law obligations.

The six-year period for contract and property tort claims does not apply to the State or its agencies unless the legislature includes them expressly or by necessary implication.

State v. Scientific Coating Co. · filed 1988-10-21

The statute of limitations for an action based on a contract or a tort to property is six years ( N.J.S.A. 2A:14-1). ... We reaffirm that a statute of limitations is not applicable to the government unless included by express language or necessary implication.

Section 2A:14-1’s six-year period does not govern a damages claim against a New Jersey municipality for its officials’ misconduct; the Tort Claims Act’s two-year period applies.

Aitchison v. Raffiani · filed 1983-05-13

Plaintiff argues that the applicable statute is NJ.Stat.Ann. § 2A:14-1 which allows six years for suits alleging “tortious injury to ... personal property, ... to the rights of another ... or for recovery upon a contractual claim or liability, expressed or implied.... ” ... Although the state supreme court has not yet spoken on the issue, the Martin and Lloyd cases present a reasonable interpretation of the Tort Claims Act which we accept as representing New Jersey law. On that basis, it is clear that had the case at hand been brought in the state court under state law, the two-year statute of limitations would apply.

Section 2A:14-1 does not apply against the State by its terms, expressly or by necessary implication.

ENVIRONMENTAL PROTECT. DEP'T. v. Ventron Corp. · filed 1981-12-09

N.J.S.A. 2A:14-1 and 10 are not by their terms applicable against the State, expressly or by necessary implication.

Section 2A:14-1 bars a damages claim against individual public officials for failing to implement relocation assistance statutes when the claim is brought more than six years after the alleged acts.

Blazer Corp. v. NJ Sports & Exposition Auth. · filed 1984-02-28

Having determined that the Tort Claims Act is applicable, it follows almost inevitably that the acts of which plaintiff complains are subject also to the limitations normally applicable to torts. If the cause of action is a tort within the purview of one statute, it is difficult to exclude it from the scope of another statute. I, therefore, hold that the cause of action as to the individual defendants is time barred by N.J.S.A. 2A:14-1.

The six-year limitations period does not bar a Port Authority claim to recover money advanced for a public purpose because the Port Authority is a state governmental agency.

PORT AUTHORITY OF NY AND NJ v. Bosco · filed 1984-05-04

There is no doubt that the Port Authority as a state governmental agency is exempt from the bar of the Statute of Limitations.

The six-year period for contract claims does not apply to uninsured motorist claims against the Port Authority, which are subject to its specific one-year limit.

Port Authority of New York v. Ingram · filed 1989-04-27

Consequently, Ingram relies on the six-year limitation period in N.J.S.A. 2A:14-1 generally applicable to all contract claims. ... Whether Ingram's claim in this case is characterized as contractual or one for personal injury governed by the two-year limitation in N.J.S.A. 2A:14-2, Ingram advances no satisfactory or persuasive reason to abandon the Authority's specific one-year blanket limitation statute.

Section 2A:14-1’s six-year limitations period does not bar claims brought by the State or its agencies and subdivisions.

NJ ED. FACIL. v. Conditioning Co. · filed 1989-12-13

Specifically, the six-year statute of limitations in N.J.S.A. 2A:14-1 does not apply to the State or any of its agencies and subdivisions.

The six-year limitations period does not bar a state agency from collecting a student loan it acquired under a statutory duty.

NJ HIGHER ED. ASSISTANCE v. Carlock · filed 1991-02-08

Had the Legislature intended the State to be bound by the six year statute of limitations in collecting on a student loan, it would have been expressly provided in the Act.

Section 2A:14-1’s six-year limitations period applies to a private ECRA claim by a land transferee against a transferor.

New West Urban Renewal Co. v. Westinghouse Electric Corp. · filed 1995-11-21

A private cause of aetion by a transferee of land against the transferor for failing to comply with ECRA is most analogous to a common law environmental tort aetion, which must be commenced within six years of its accrual.

Section 2A:14-1’s six-year limitations period does not apply to malicious prosecution claims against a public entity; the New Jersey Tort Claims Act’s two-year period applies.

Michaels v. State of NJ · filed 1996-11-08

Michaels further contends, also erroneously, that New Jersey’s six-year statute of limitations, N.J.S.A. 2A:14-1, applies to her malicious prosecution claim. Because the City of Newark is a public entity within the meaning of the New Jersey Tort Claims Act, however, all of plaintiffs state law claims asserted against it, including plaintiffs malicious prosecution claim, are subject to the Act’s two-year statute of limitations, N.J.S.A. 59:8-8(b).

Section 2A:14-1 gives employees six years to bring private claims for unpaid prevailing wages because those claims seek recovery for economic harm.

Troise v. Extel Communications, Inc. · filed 2001-11-21

Therefore, in the absence of a legislative directive to apply another more specific limitations provision, we are satisfied that a private cause of action under the Act is subject to the six-year limitations period provided by N.J.S.A. 2A:14-1 for breach of contract and tort claims for economic harm.

Section 2A:14-1 supplies a six-year limitations period that the court borrowed for a claim alleging a violation of the federal bankruptcy automatic stay.

In Re Bernheim Litigation · filed 2003-02-28

Based on the character of Bernheim’s claims, the Court concludes that the six-year New Jersey limitations period is the most appropriate statute to apply to the section 362(h) claim.

Section 2A:14-1’s six-year limitations period applies to a duty of fair representation claim brought in court under New Jersey’s Employer-Employee Relations Act.

Farber v. City of Paterson · filed 2006-03-08

In sum, we will follow Gomez and will affirm the conclusion of the District Court that New Jersey’s six-year statute of limitations “for any tortious injury to the rights of another,” N.J. Stat. Ann. § 2A:14-1, applies to a DFR claim brought in court.

The six-year limitations period applies to claims against publicly employed attorneys that accrued before July 1, 1994, and to intentional tort claims against them that accrued before June 29, 2004.

Stoeckel v. Township of Knowlton · filed 2006-06-09

We hold that the six-year statute of limitations found in N.J.S.A. 2A:14-1 applies to all claims against publicly employed attorneys which accrued prior to July 1, 1994. That limitations period continues to apply to causes of action for tortious intentional conduct by a publicly employed attorney which accrued prior to June 29, 2004.

Section 2A:14-1 gives a landowner six years to bring an inverse condemnation claim, beginning when the landowner knew or reasonably should have known that the taking deprived the property of all reasonably beneficial use.

Raab v. Borough of Avalon · filed 2007-04-30

We further hold that a cause of action against a governmental defendant to recover the value of the real property that was taken by inverse condemnation is governed by the provisions of N.J.S.A. 2A:14-1 -2, and must be filed within six years from the date of accrual, which is defined as the date the landowner becomes aware or, through the exercise of reasonable diligence, should have become aware, that he or she had been deprived of all reasonably beneficial use of the property.

Section 2A:14-1’s six-year period applies to economic claims for unpaid wages and commissions under the WPL and SRA.

Meyers v. Heffernan · filed 2010-09-24

Consequently, the six-year statute of limitations of N.J.S.A. § 2A:14-1 applies to plaintiffs’ claims under the WPL and SRA.

The six-year limitations period applies to medical providers’ claims for payment even after those claims became subject to the Division of Workers’ Compensation’s exclusive jurisdiction.

THE PLASTIC SURGERY CENTER, PA VS. MALOUF CHEVROLET-CADILLAC, INC. THE PLASTIC SURGERY CENTER, PA VS. LEONE INDUSTRIES T · filed 2019-01-17

If anything, the belief that the Legislature was already satisfied with existing procedural requirements for these claims more logically suggests it ... intended that the six-year statute of limitations, which undoubtedly applied to medical-provider claims prior to the amendment, would continue to apply after the amendment was enacted.

Section 2A:14-1 gives medical providers six years from accrual to bring payment claims for services rendered to injured workers, even when those claims must be filed in the Division of Workers' Compensation.

Plastic Surgery Ctr., PA v. Malouf Chevrolet-Cadillac, Inc. · filed 2019-01-17

Absent some clearer expression from the Legislature, the timeliness of medical-provider claims is to be assessed by resort to N.J.S.A. 2A:14-1.

Section 2A:14-1 gives a Consumer Fraud Act claim six years from accrual, which occurs when the claimant knew or reasonably should have known it had an actionable claim.

THE OZ CONDOMINIUM ASSOCIATION, INC. VS. OZ, LLC (L-2508-14, HUDSON COUNTY AND STATEWIDE) · filed 2019-07-17

Thus, plaintiff was or should have been aware that it may have an actionable claim as early as 2004, ten years before it filed the complaint, and we find plaintiff's CFA claims are barred under the six-year statute of limitations.

Section 2A:14-1 gives fraud claims a six-year limitations period that begins when the plaintiff discovers the wrong or facts that reasonably should prompt an inquiry into the fraud.

KACHUR v. WMC MORTGAGE CORPORATION · filed 2019-08-14

Both causes of action have a six-year statute of limitations that “begins to run on discovery of the wrong or of facts that reasonably should lead the plaintiff to inquire into the ... fraud.” N.J.S.A. § 2A:14-1; S. Cross Overseas Agencies, Inc. v. Wah Kwong Shipping Grp. Ltd., 181 F.3d 410, 425 (3d Cir. 1999). ... Thus, the Court cannot conclude that the statute of limitations bars these claims.

Section 2A:14-1 gives Consumer Fraud Act claims a six-year limitations period; a claim based on foreclosure proceedings ongoing when the complaint was filed is timely.

D'ANGELO VS. OCWEN LOAN SERVICING, LLC (L-1934-14, UNION COUNTY AND STATEWIDE) · filed 2020-05-08

Thus, the CFA claim based on the proceedings in the 2008 and 2012 foreclosure actions was timely filed within the six-year limitations period in N.J.S.A. 2A:14-1.

The six-year limitations period for a fraud claim begins when the plaintiff discovers, or reasonably should discover, the fraud; Saminvest’s claim did not accrue until April 2, 2009.

BERLIN CROSS KEYS SHOPPING CENTER ASSOCIATES, LLC VS. STEPHEN SAMOST, ESQUIRE (L-5114-12, CAMDEN COUNTY AND STATEWIDE) · filed 2020-07-22

Applying those facts to the Lopez considerations, see Berlin I, slip op. at 18 (quoting Lopez, 62 N.J. at 275-76), compels our affirming the trial court's decision, substantially for the reasons stated by the trial court in its thorough oral decision as we too conclude that Saminvest's cause of action did not accrue until April 2, 2009.

The six-year limitations period continues to govern medical providers’ claims for payment for services to injured workers after the 2012 amendment to N.J.S.A. 34:15-15.

The Plastic Surgery Center, PA v. Malouf Chevrolet-Cadilac, Inc. (082502) (Statewide) · filed 2020-02-03

The judgment of the Superior Court, Appellate Division is affirmed substantially for the reasons expressed in Judge Fisher’s opinion, reported at 457 N.J. Super. 565 (App. Div. 2019). As the Appellate Division noted, in the 2012 amendment to N.J.S.A. 34:15-15, the Legislature did not expressly address the statute of limitations.

Section 2A:14-1 provides a six-year limitations period for unjust enrichment and New Jersey Consumer Fraud Act claims, subject to the discovery rule.

KATZ v. AMBIT NORTHEAST, LLC. · filed 2021-06-29

Because Katz first brought this action on December 10, 2019, if Katz discovered, or with reasonable diligence should have discovered, that he might have a basis for his unjust enrichment and fraud claims before December 10, 2013, or his invasion of privacy claim before December 10, 2017, then these claims would be barred by the applicable statutes of limitations. ... Therefore, the Court declines to dismiss Katz’s claims for being time-barred.

Section 2A:14-1 does not bar a pension board from deducting loan repayments from pension payments when the board has brought no action at law.

ZILBERBERG VS. BOARD OF TRUSTEES (TEACHERS' PENSION AND ANNUITY FUND) · filed 2021-06-22

Zilberberg argues that the Board's deduction of the principal and balance from her pension payments is barred by N.J.S.A. 2A:14-1, which addresses the statute of limitations for actions in breach of contract. However, since the Board has not taken an action at law against Zilberberg, no statute of limitations is implicated here.

Section 2A:14-1 does not bar deductions from pension payments when the Board has brought no action at law.

ZILBERBERG VS. BOARD OF TRUSTEES (TEACHERS' PENSION AND ANNUITY FUND) · filed 2021-07-02

Zilberberg argues that the Board's deduction of the principal and balance from her pension payments is barred by N.J.S.A. 2A:14-1, which addresses the statute of limitations for actions in breach of contract. However, since the Board has not taken an action at law against Zilberberg, no statute of limitations is implicated here.

Section 2A:14-1 governs the limitations period for tort-based property damage claims and does not create a cause of action.

NAPRSTEK v. DITECH FINANCIAL LLC · filed 2022-07-19

Beginning with Plaintiff’s claim for intimidation and property damage, section 2A:14-1 does not provide for a cause of action. Instead, it is a statute of limitation governing tort-based property damage claims.

Section 2A:14-1's six-year limitations period applies to private causes of action under the New Jersey Wage Payment Law.

Cruz v. Aspen Landscaping Contracting Inc. · filed 2024-12-27

We therefore conclude private causes of action under the WPL are subject to the six-year statute of limitations in N.J.S.A. 2A:14-1.

The six-year limitations period applies to wage claims under the New Jersey Wage Payment Law because they are comparable to contract claims or tort claims for economic harm.

Carlson v. Weber · filed 2025-10-29

We are nevertheless persuaded that a claim for wages arising under the WPL is comparable to a claim for breach of contract or a tort claim for economic harm such that it should be subject to the six-year limitations period provided by N.J.S.A. 2A:14-1.

Section 2A:14-1 provides a six-year limitations period for Prevailing Wage Act claims treated as breach-of-contract claims.

Martinez v. T. Slack Environmental Services, Inc. · filed 2026-06-29

Consequently, statutory claims under the PWA are comparable to a claim for "breach of contract or other economic harm" such that they should be "subject to the six-year limitations period provided by N.J.S.A. 2A:14-1 for breach of contract."

Section 2A:14-1’s six-year limitations period does not apply to private contribution claims under the Spill Act.

Morristown Associates v. Grant Oil Company (073248) · filed 2015-01-26

Based on the plain language of the Spill Act, reinforced by its legislative history, we hold that N.J.S.A. 2A:14-1’s six-year statute of limitations is not applicable to Spill Act contribution claims.

Section 2A:14-1’s general six-year limitations period yields to the specific two-year period in N.J.S.A. 59:8-8 for a civil rights damages action against a municipality.

Gipson v. Township of Bass River · filed 1979-04-05

The court finds that the specific limitation provided in N.J.S.A. 59:8-8 controls over the more general provisions of N.J.S.A. 2A:14-1 or 14-2 and thus is more appropriate.

Section 2A:14-1 allows six years from accrual to bring a contractual claim; an indemnity claim accrues when the indemnitee’s liability is fixed by judgment or payment.

United New York Sandy Hook Pilots Association v. Rodermond Industries, Inc. · filed 1968-03-22

The New Jersey statute of limitations provides, in relevant part, that 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.' N.J.Stat.Ann., supra. The general rule, applicable to this case, is that a claim for indemnity does not accrue until the indemnitee's liability is fixed by a judgment against or payment by the indemnitee.

Section 2A:14-1 gives a plaintiff six years to bring a contract claim; an insured’s claim for reimbursement of defense costs accrues when the third-party action ends and the full costs can be determined.

Kielb v. Couch · filed 1977-04-27

The six-year statute of limitations governing actions for recovery upon a contractual claim is applicable to plaintiff's cause of action. ... Our conclusion is that plaintiff's cause of action for reimbursement of defense costs did not accrue until the termination of the third-party action brought against him. ... Accordingly, plaintiff's action was commenced within the six-year limitation.

Section 2A:14-1 does not bar a claim against a person who is both guarantor and indorser of a demand note when the action is filed within six years of the maker’s default while the maker remains liable.

Central Jersey Bank & Trust Co. v. Lady Van Indus., Inc. · filed 1977-11-21

N.J.S.A. 2A:14-1, which is the six-year, statute of limitations, requires that this action "shall be commenced within six years next after the cause of ... action shall have accrued." ... The within action having been commenced less than six years after default by the maker, and during the time when the liability of the maker has not been extinguished, as well as, within the limitation applicable to indorsers, the defense of the statute of limitations is not available to the defendant Fusari, who is an indorser as well as guarantor.

The six-year limitations period begins when the claimant has an enforceable right; on these facts, a claim to compel assignment of patent rights accrued when the divisional patents issued.

Andreaggi v. Relis · filed 1979-03-13

For purposes of determining when a cause of action accrues so that the applicable period of limitation commences to run, the relevant question is when did the party seeking to bring the action have an enforceable right. ... The court finds that, on the facts herein, the issuance of the divisional patents was the first event from which the period of limitations should commence to run. At that time plaintiffs knew that they had patents in which another could assert an interest. They did commence this action within two years, not six years, of that date. The court concludes that the statute of limitations is not a defense.

The six-year limitations period for a bank's conversion of negotiable instruments is subject to the discovery rule.

DeHart v. First Fidelity Bank, NA/South Jersey · filed 1986-12-02

This court does not perceive any pragmatic or metaphysical distinction between this case and those where the discovery rule has been applied to N.J. Stat.Ann 2A:14-1 which would warrant a refusal to apply the rule in the context of transactions involving negotiable instruments under the Uniform Commercial Code. This court therefore holds that the discovery rule applies to an action against a bank for conversion of negotiable instruments under the Uniform Commercial Code.

Section 2A:14-1 allows six years from the accrual of a tort claim, which occurs when consequential injury or damage occurs.

Hermes v. Staiano · filed 1981-09-11

It has long been established in New Jersey that a cause of action grounded in tort accrues, not when the tortious act occurs but when the consequential injury or the damage occurs. ... Under the circumstances it is evident from the proofs submitted that plaintiffs' cause of action did not accrue until well within six years prior to the filing of the complaint.

The six-year limitations period applies to a passbook savings account, but begins when the depositor demands payment rather than when the deposit is made.

Pagano v. United Jersey Bank · filed 1994-10-11

We first address defendant's claim of applicability of the six-year statute of limitations, N.J.S.A. 2A:14-1. We have no doubt that the transaction is indeed subject to that limitations period. The question is when the statutory period starts to run. We think it plain that the triggering event is hardly the making of the deposit itself. It is, rather, the depositor's demand for payment.

A claim subject to the six-year limitations period may survive dismissal when factual issues remain about whether the defendant concealed the right to sue.

Levitt v. Riddell Sports, Inc. (In Re MacGregor Sporting Goods, Inc.) · filed 1995-11-27

For the same reasons applicable to Count Three as set forth above, this Court must deny Brooks’ motion to dismiss. Whether Brooks engaged in any conduct which would conceal the right to institute a cause of action against him for his role in negotiating the 1989 Transaction involves genuine issues of material fact which precludes dismissal or summary judgment.

The six-year period for a third-party beneficiary’s contract claim can begin when the beneficiary discovers or reasonably could have discovered the breach.

Sodora v. Sodora · filed 2000-12-18

The precise issue then becomes whether this action is barred by the failure of the parties to bring suit within the six year statutory period as set out in N.J.S.A. 2A:14-1. ... In short, I am satisfied that the discovery rule applies to third-party beneficiaries of contracts and that plaintiffs' factual assertions raise a sufficient factual dispute as to compel the denial of the motion for summary judgment.

Section 2A:14-1 gives a party six years to bring a contractual indemnity claim; a claim for loss accrues when payment discharges the liability and the indemnitee suffers an actual loss.

FIRST INDEM. INS. CO. v. Kemenash · filed 2000-02-10

Recovery on express or implied contractual claims or liability not under seal is governed by N.J.S.A. 2A:14-1, which provides that such action must be commenced within six years "after the cause of any such action shall have accrued." Where the agreement indemnifies for loss, the cause of action accrues at the point that the liability is discharged by payment and the indemnitee suffers an actual loss.

The six-year limitations period is tolled while a medical provider’s claim is pending in the Division of Workers’ Compensation.

MEDICAL DIAGNOSTIC v. Hawryluk · filed 1998-12-30

The statute of limitations is six years. See N.J.S.A. 2A:14-1. We note that there is no statutory provision tolling the statute of limitations on the medical provider's claim while an employee's claim is pending in the Division. We are satisfied, however, that if a medical provider's suit is transferred to the Division, as we hold today, the complaint will have been timely filed. In future cases in which the medical provider proceeds directly in the Division the statute of limitations will be tolled during the period that the matter is pending in the Division.

For a condominium association’s claim for assessments due from a purchaser, the six-year limitations period begins when the sheriff’s deed is delivered, rather than when the bid is accepted.

CKC CONDOMINIUM ASSOCIATION, INC. v. Summit Bank · filed 2000-11-29

Ownership occurs when a recordable document is delivered. That happened here when the sheriff executed and delivered his deed to Pipco. That took place within the six-year limitations period.

The six-year limitations period for a quantum meruit claim runs from the last rendition of services; the discovery rule does not delay it.

Robert v. Baer v. David Chase Chase Films Inc., a Delaware Corporation John Does A-Z · filed 2004-12-21

It is clear that any application of the discovery rule would be inappropriate in analyzing whether the statute of limitations ran on Baer’s quantum-meruit claim. The district court was therefore correct in utilizing a last rendition of services test to analyze whether Baer’s claim was time barred.

The six-year limitations period for New Jersey state law claims begins to run when a reasonable person exercising ordinary diligence would know of the injury and another’s fault.

CETEL v. KIRWAN FINANCIAL GROUP · filed 2006-08-28

Both parties agree that these claims are governed by New Jersey state law, which applies a six-year statute of limitations. N.J.S.A. § 2A:14-1; Mirra v. Holland America Line, 331 N.J.Super. 86, 751 A.2d 138 (2002); ... We thus have no trouble agreeing with the District Court that, by August 1995, for purposes of plaintiffs' state law claims, the statute of limitations had begun to run.

Section 2A:14-1 gives six years to bring an accounting malpractice claim from accrual. A corporation can avoid having rogue managers’ knowledge imputed to it for limitations purposes by showing that they completely abandoned its interests and that it received no benefit from their fraud.

NCP Litigation Trust v. KPMG · filed 2007-06-22

N.J.S.A 2A:14-1 provides that an action for accounting malpractice shall be filed six years from the date that it accrues. ... The discovery rule provides that a cause of action only accrues when the plaintiff becomes aware, or reasonably should become aware, that he has suffered harm. ... In sum, the court holds that in order to avoid imputing the knowledge of PCN's rogue managers to PCN, the Trust must show 1) that the rogue managers had completely abandoned the interests of PCN with respect to the fraudulent transactions, and 2) that PCN received no benefit from the fraudulent transactions.

The six-year period for a contract claim begins when a party repudiates the agreement and indicates that future performance will not comply with its terms.

R.C. Beeson, Inc. v. Coca Cola Co. · filed 2009-07-13

In other words, a combination of an act deliberately repudiating the agreement and an act indicating to the non-breaching party that any future performance either will not occur or will not be in compliance with the contract terms commences the running of the statute of limitations.

The six-year limitations period begins when a cause of action accrues, which requires an injury; the claims here accrued when the Estate obtained a legal interest in the annuity.

Kanter ex rel. Estate of Schwartz v. Equitable Life Assurance Society · filed 2010-02-05

Plaintiffs causes of action did not accrue until September 14, 2001, and her complaint, docketed August 1, 2007, was timely filed within six years.

The six-year limitations period is subject to the discovery rule; recording a mortgage alone does not put existing owners on notice of a claim arising from its fraudulent execution.

SOMERVILLE TIC II, LLC VS. DAVID HAY (L-1160-16, SOMERSET COUNTY AND STATEWIDE) · filed 2018-08-20

The existence of the properly recorded Bank Mortgage was insufficient to put plaintiffs on notice and the trial court's failure to conduct a Lopez hearing was plain error, capable of producing an unjust result, and we remand for that purpose.

A claim for an unpaid commission does not accrue under the six-year limitations period until the commission is due and payment is withheld.

BERKELY RISK SOLUTIONS, LLC VS. INDUSTRIAL RE-INTERNATIONAL, INC.(L-0163-15, UNION COUNTY AND STATEWIDE) · filed 2017-09-20

The cause of action could not have accrued until the 2009-10 policy commission became due, and AFU failed to pay defendants the sixty-percent they claim was due to them.

Section 2A:14-1 gives a party six years to bring a contract claim; the period did not bar a claim filed within months of the plaintiff’s first reasonable indication that his ownership interest was disputed.

ANTHONY MARRA, ETC. VS. MITCHELL T. BERLANT (C-012067-11, SOMERSET COUNTY AND STATEWIDE) · filed 2017-11-06

Contract claims have a six-year SOL. N.J.S.A. 2A:14-1. ... The record demonstrates plaintiff's first objectively reasonable indication that he was not considered a member of MRA occurred in the spring of 2011, when he stopped receiving his monthly loan repayment checks, and when he received a series of correspondence from Mitchell. He filed suit in August 2011, within months of learning of the Berlants' position. Whether considering his actions under the SOL or laches, plaintiff's actions were reasonable.

The six-year limitations period bars a claim filed more than six years after the claimant knew the facts supporting it.

BRIDGETON COMMERCE CENTER VS. NJ DEALERS AUTOMALL, INC.(L-5292-05, MONMOUTH COUNTY AND STATEWIDE) · filed 2017-11-02

The uncontradicted evidence presented at the Lopez hearing amply supported the judge's conclusion that Altman was fully aware he was not a 50% owner of NJDAM more than six years before plaintiffs filed their complaint. ... Therefore, the judge correctly dismissed count six of the complaint on statute of limitations grounds.

Section 2A:14-1 sets a six-year period for negligent construction, breach of contract, and consumer fraud claims; the discovery rule can delay accrual of a construction defect claim.

COLLINS VS. PJW SERVICES, LLC (L-2766-17, CAMDEN COUNTY AND STATEWIDE) · filed 2021-07-26

The statute of limitations for claims alleging negligent construction, breach of contract, and consumer fraud is six years. N.J.S.A. 2A:14-1. ... In sum, plaintiffs' claims were not barred by the six-year statute of limitations because the cause of action accrued in 2014.

The six-year limitations period begins when a claim accrues; deciding whether the discovery rule delays accrual may require further factual development.

DEWULF v. BLATT BILLIARD CORP. · filed 2023-05-02

Unlike the laches clock, which begins to run when a plaintiff knows or should know about the existence of a provable claim, the statute of limitations begins to run upon accrual of the cause of action. See N.J. Stat. § 2A:14-1. ... The record is not sufficiently developed to justify such a determination at this time. I will therefore deny the motion for judgment on the pleadings as to Counts 2 and 3 as well.

The six-year limitations period for contract and quasi-contract claims begins when the claim accrues; policy-period dates alone do not establish when it began.

ARCH SPECIALTY INSURANCE COMPANY v. CJS PLUMBING, INC. · filed 2021-06-09

The clock begins to tick on the date the cause of action accrues. N.J. Stat. Ann. § 2A:14-1.

Section 2A:14-1 gives six years to file a breach of contract claim; an attorney’s claim for unpaid fees accrues when the services conclude or the attorney-client relationship ends, whichever occurs first.

GRABOWSKI VS. WILLIAM BASKAY (L-0736-19, BURLINGTON COUNTY AND STATEWIDE) · filed 2021-07-09

N.J.S.A. 2A:14-1 requires that a claim for breach of contract be filed within six years from the date the cause of action accrues. ... In Protopapas, which governs this attorney-fee collection matter, we set forth a bright line rule that a cause of action accrues for unpaid counsel fees between an attorney and client "when the services are concluded or [the] attorney-client relationship is ended, whichever occurs first." Id. at 145.

Section 2A:14-1 gives six years to bring a contract claim; whether additional rent is untimely depends on when the payments fell due.

PIER 541 LLC v. THE CRAB HOUSE, INC. · filed 2021-09-28

Under New Jersey law, “[e]very 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.” N.J.S.A. 2A:14–1. ... Indeed, neither party has meaningfully addressed when additional rent payments would have fallen due under Paragraph 4.03 if it binds Crab House—i.e., on a monthly basis when Crab House’s ordinary rent payments were due and payable, or otherwise. Accordingly, the issue is not ripe for summary disposition.

The six-year limitations period for contribution and indemnification claims does not begin before an underlying judgment against the claimant.

RGD HOLDING COMPANY, LLC v. PERKINS · filed 2022-02-28

Without such a judgment, the statute of limitations for neither Plaintiff’s claim for indemnification, nor its claim for contribution has accrued.

Section 2A:14-1’s six-year period begins when the contract claim accrues; an earlier target date does not start the period when the alleged breach occurred later.

FUREY v. LEONARD BUCK TRUST (L-0332-18, SOMERSET COUNTY AND STATEWIDE) · filed 2022-07-21

We note only plaintiffs' claims are not founded on the Trust's failure to obtain a Final RAO by September 8, 2003, and, as we have explained, paragraph 2(a)(6) did not mandate that the groundwater remediation be completed by that date. Rather, in paragraph 2(a)(6), the parties anticipated the groundwater remediation might not be completed by that date. ... Thus, plaintiffs' claims first accrued in 2016, and their complaint was timely filed in 2018.

Section 2A:14-1(a) gives a party six years after a contract claim accrues to sue; a breach of contract claim accrues when the alleged breach occurs.

CONTINENTAL CASUALTY COMPANY v. J.M. HUBER CORPORATION · filed 2022-11-30(a)

Therefore, CNA’s right to file the present suit arose on April 12, 2012 and CNA did so well within the six-year limitation period by filing suit on July 12, 2013. JM Huber’s position implies that a cause of action can accrue before an alleged breach, which is inconsistent with the plain text of the statute.

The six-year limitations period applies to a constructive-trust claim for custodial property, and the discovery rule can delay when that period begins.

HUNY & BH ASSOCIATES, INC. VS. AVI SILBERBERG (L-10677-15, BERGEN COUNTY AND STATEWIDE) · filed 2021-12-27

We conclude that the six-year limitations period "for taking, detaining, or converting personal property" is appropriate. N.J.S.A. 2A:14-1. But we also conclude — as the trial court implicitly did — that the discovery rule applies.

The six-year period applies to fraud and participation in breach of fiduciary duty claims, subject to the discovery rule, which can delay accrual.

Sanford v. Pershing LLC · filed 2024-04-23

Under New Jersey law, both fraud and participation in breach of fiduciary duty claims are subject to a six-year statute of limitations.1 N.J.S.A. § 2A:14–1; ... Because reasonable minds could differ as to when Sanford discovered, or should have reasonably discovered, his injury, the Court cannot say as a matter of law that limitations began to run in February 2009.2 Accordingly, the Court denies summary judgment on this ground.

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

COUNTRY CLUB DRIVE ASSOCIATES, LLC v. CLINTON TOWNSHIP · filed 2024-06-17

The discovery rule “tolls the limitations period until the plaintiff learns of [its] cause of action or with reasonable diligence could have done so” and “is an exception to the usual principle that the statute of limitations begins to run immediately upon accrual regardless of whether or not the injured party has any idea what has happened to [it].” ... A brief review of the underlying facts as alleged in the amended complaint and attached exhibits demonstrates that this claim is not suitable for dismissal at this early stage. ... Defendant here has demonstrated that there is a significant factual question here as to when Plaintiff knew or reasonably should have known as to the existence of its negligence claim against MMD; however, drawing all reasonable factual inferences in Plaintiff’s favor means that Defendant cannot meet the high bar to prevail on its motion to dismiss.

Section 2A:14-1 provides a six-year limitations period for fraud and aiding and abetting fraud claims; a factual dispute over when a plaintiff discovered the claim can prevent summary judgment on timeliness.

McLeod v. Pershing LLC · filed 2024-07-08

Accordingly, the Court cannot hold as a matter of law that limitations began to run in February 2009.

The limitations period for a breach of contract claim begins when the cause of action accrues, so the default date affects whether the claim is time-barred.

STROMBERG v. MIDLAND FUNDING LLC · filed 2024-04-18

Since the statute of limitations for breach of contract commences when the cause of action accrues, see, e.g., N.J.S.A. § 2A:14–1, the date of default impacts whether the debt is time-barred.

Section 2A:14-1(a) gives a plaintiff six years from accrual to file contract, unjust enrichment, or quantum meruit claims.

Kissi v. Ansah · filed 2024-04-29(a)

Plaintiff's claims for breach of contract, unjust enrichment and quantum meruit are all subject to a six-year statute of limitations. Plaintiff's October 21, 2020 initial complaint was not filed within six years of accrual, based upon the allegations in plaintiff's complaint and his factual admissions on the record.

Section 2A:14-1 gives breach-of-contract claims a six-year limitations period.

BYRD v. INVENTIV HEALTH · filed 2024-04-29

However, that claim cannot succeed because the statute of limitations for claims for breach of contract in New Jersey is six (6) years. See N.J. Stat. § 2A:14-1. ... Therefore any breach-of-contract claim as to the Syneos Defendants is outside the six-year statute of limitations and is time barred under New Jersey law.

Section 2A:14-1 provides a six-year limitations period for claims under a license agreement rather than a contract for the sale of goods.

BENJAMIN MOORE & CO. v. B.M. MEDITERRANEAN S.A. · filed 2024-10-28

The claims in this action are premised upon the parties’ relationship pursuant to the License Agreement, not a contract for a sale of goods. As such, the applicable statute of limitations is the six-year statute of limitations pursuant to N.J. Stat. Ann. § 2A:14-1.

The six-year period for a breach of contract claim runs from the breach; the continuing breach doctrine does not extend it when the complaint alleges a single cessation of performance.

Unbeatablesale.com, Inc. v. LJM Supplies Corp. · filed 2026-01-29

The Court, accordingly, finds that the continuing breach doctrine does not apply to Plaintiff’s breach of contract claim as currently alleged. Plaintiff was obligated to file this lawsuit within six years of the breach of contract, and Plaintiff failed to do so. Plaintiff’s claim is therefore dismissed as time-barred.

For environmental contamination claims, the six-year period begins as to each defendant when the plaintiff knows or reasonably should know of the injury and that defendant’s identity as a potentially liable party.

Allied Corp. v. Frola · filed 1990-02-14

Analyzing the conflicting case law from the New Jersey Supreme Court—the weight of which emphasizes the importance of the identification of responsible parties—this Court holds that, at least in an environmental contamination case, a cause of action accrues in New Jersey when a plaintiff knows or reasonably should know of his or her cause of action and of the identity of a party or parties who may be responsible for the injury, in this case the dumping of hazardous substances on land. When there are numerous defendants, as there frequently are in environmental contamination cases, a plaintiff’s cause of action as against each defendant accrues when he or she knows or reasonably should know the identity of that defendant as a potentially liable party.

The six-year limitations period for environmental contamination claims begins when plaintiffs know or reasonably should know of the contamination and who may be responsible; an inconclusive investigation does not necessarily start the period.

Bowen Engineering v. Estate of Reeve · filed 1992-09-17

Under the facts of this case, the DEP’s initial investigation of the North Branch site did not put plaintiffs on notice that they had any of the three causes of action remaining for consideration. ... This fact did not come to light until the DEP prepared its report in April of 1989, less than two months before plaintiffs filed their complaint. Thus, the complaint was filed in a timely fashion under the applicable statute of limitations.

Section 2A:14-1 gives a plaintiff six years to bring a common-law environmental tort claim; under the discovery rule, knowledge of contamination alone does not start the period without knowledge that another party may be at fault.

SC Holdings, Inc. v. A.A.A. Realty Co. · filed 1996-08-16

We cannot endorse this overbroad interpretation of the discovery rule; nor can we determine as a matter of law that SCH should have known of other parties’ fault on or before June 20, 1988, when nothing before me suggests that SCH knew anything more than the landfill had been closed and the Site was contaminated.

Section 2A:14-1’s six-year period is not tolled for environmental contamination claims once indications of contamination give the plaintiff reasonable notice to investigate; actual sampling results are unnecessary.

New West Urban Renewal Co. v. Viacom, Inc. · filed 2002-11-18

Thus, with respect to environmental claims, tolling under the discovery rule is not dependent on whether actual sampling results have been taken, but whether there are enough indications of environmental contamination to put the plaintiff on reasonable notice of a need to investigate further. ... After reviewing the summary judgment record, I find that there is no genuine issue of material fact that the claims upon which Viacom seeks summary judgment are barred under the six-year statute of limitations, N.J.S.A. § 2A:14-1.

The six-year limitations period did not warrant summary judgment on the property tort claims because the court found that the continuing threat from contamination and the timing of the claims required further consideration.

Interfaith Community Organization v. Honeywell International, Inc. · filed 2002-07-26

According to this statute, the limitations period is six years. ... While Honeywell is correct that the present record supports the conclusion that the Grace Defendants became aware of chromium contamination at the Site in or around 1983, this Court finds that this issue should not be adjudged as a matter of law.

The six-year limitations period bars contamination claims unless a continuing tort gives rise to a new injury or breach of duty within that period.

Haddonbrook Associates v. General Electric Co. · filed 2011-05-04

While it is true that contaminants may continue to flow onto Haddonbrook’s property, the District Court correctly concluded that Haddonbrook failed to claim or adduce evidence of any compensable injury occurring within the limitations period.

Section 2A:14-1’s six-year period applies to construction-contract arbitration demands and, under the discovery rule, begins when the claimant knows of the injury and another party’s fault, even if the exact cause remains unknown.

Torcon, Inc. v. Alexian Brothers Hospital · filed 1985-07-26

This Court finds there is no legitimate reason to hold that the discovery rule is inapplicable to cases involving a Demand for Arbitration under a construction contract in the appropriate circumstances, in view of the expanding employment of the discovery rule. ... The Court finds that once a party knows it has been injured and that said injury is the fault of another it has the requisite knowledge for the applicable period of limitations to commence running.

Section 2A:14-1’s six-year period applies to tort claims for defective construction, including the negligence, breach of warranty, and strict liability claims at issue here.

Bergen Commun. College Trustees v. FYFE · filed 1982-10-07

Plaintiff complaint sounds in negligence, breach of warranty and strict liability in tort. All are tort causes of action and the statute of limitations, N.J.S.A. 2A:14-1, applies to "any tortious injury." It follows that the six-year statute controls.

Section 2A:14-1 gives a claimant six years to bring a strict liability claim for injury to real property; the period runs when the claimant knows or reasonably should know the material facts supporting the claim.

Hatco Corp. v. W.R. Grace & Co.—Conn. · filed 1992-07-27

The Court finds as a matter of law that such diligence would have revealed facts sufficient to equate in law with Hatco’s strict liability claim more than six years before Hateo filed this action in 1989. Accordingly, the Court concludes that Hatco's strict liability claim is time-barred by the six-year statute of limitations in N.J.S.A. 2A:14-1.

The six-year period for a condominium association’s construction-defect claims begins when unit owners control its board and the board has enough facts to assert actionable claims.

STATE OF NEW JERSEY VS. JOSHUA M. GREEN (12-02-0322, MIDDLESEX COUNTY AND STATEWIDE)(RECORD IMPOUNDED) · filed 2017-08-21

We are convinced that, under the circumstances presented in this case, plaintiff's causes of action did not accrue until the unit owners took full control of the Association's governing Board, and the Board had sufficient facts upon which to assert actionable claims against defendant contractors.

In a construction-defect case, § 2A:14-1’s six-year period begins when the first owner in the chain of ownership knows or reasonably should know of an actionable claim against an identifiable party.

The Palisades at Fort Lee Condominium Association, Inc. v. 100 Old Palisades, LLC · filed 2017-09-14

A cause of action, for purposes of N.J.S.A. 2A:14-1, accrues when someone in the chain of ownership first knows or reasonably should know of an actionable claim against an identifiable party.

A claim based on a surveying error does not accrue under § 2A:14-1 until the error is discovered or reasonably discoverable.

E. A. Williams, Inc. v. Russo Development Corp. · filed 1980-02-20

As noted, N.J.S.A. 2A:14-1, the conventional statute of limitations, was not pleaded as an affirmative defense to plaintiff’s action. It would in no event under the facts of this case serve to bar plaintiff’s claim. ... Throughout all stages of this controversy, plaintiff has maintained that he did not discover Koestner’s error until 1972, and that he could not have reasonably discovered the error prior to that date. ... His cause of action did not accrue until 1972.

The six-year limitations period begins when reasonable diligence could reveal the basis for a claim; a buyer’s failure to investigate known environmental concerns does not delay it.

SUNWAY EQUITY, LLC v. SUBURBAN PROPANE, LP (L-0458-17, SOMERSET COUNTY AND STATEWIDE) · filed 2022-01-12

They do not dispute that the six-year statute of limitations under N.J.S.A. 2A:14-1 applies to their claim. ... The clock began on April 11, 2000, when Gail took ownership of the property and plaintiffs reasonably could have known of its contamination had they exercised due diligence.

The six-year limitation period for legal malpractice claims is subject to the discovery rule: accrual depends on when the plaintiff knew or should have known of an injury that might be attributable to the attorney.

Mant v. Gillespie · filed 1983-03-30

The parties do not dispute that the Mants' claim is subject to the six-year limitation fixed by N.J.S.A. 2A:14-1. ... We perceive no reason why the discovery rule should not be equally applicable to a legal malpractice cause of action.

The six-year period for legal malpractice claims runs separately for distinct claims based on when each was discovered.

Aykan v. Goldzweig · filed 1989-10-11

It is undisputed that the complaint in this legal malpractice action was filed on August 2, 1988, and that the relevant Statute of Limitations under N.J.S.A. 2A:14-1 is six years. ... It is the finding of this court therefore, that the plaintiff's claim, set forth in the complaint, for liability based on the drafting of the separation agreement be dismissed pursuant to the Statute of Limitations. The claim for failure to plead marital tort may continue.

The six-year limitations period for a legal malpractice claim arising from an underlying lawsuit begins when the appeal ends or the time to appeal expires.

Grunwald v. Bronkesh · filed 1992-02-27

Consequently, we hold that the six-year statute of limitations with respect to plaintiff's legal malpractice action against defendants did not begin to run until the appellate process was complete, and that, therefore, this action is not time-barred.

The six-year limitations period for legal malpractice begins when the client suffers damage and discovers, or reasonably should discover, that it is attributable to the attorney's negligent advice.

Grunwald v. Bronkesh · filed 1993-03-22

Therefore, we conclude that the discovery rule applies in legal-malpractice actions: the statute of limitations begins to run only when the client suffers actual damage and discovers, or through the use of reasonable diligence should discover, the facts essential to the malpractice claim.

The six-year period for legal malpractice begins when the client suffers actual damage and knows or reasonably should know the facts supporting the claim.

Limor v. Weinstein & Sutton (In Re SMEC, Inc.) · filed 1993-10-27

New Jersey has a six-year statute of limitations for legal malpractice actions. N.J.Stat.Ann. § 2A:14-1 (West 1987). ... On the basis of these facts, the earliest date that the statute of limitations could have begun to run was September 25, 1984. Six years from that date was September 25, 1990.

A genuine factual dispute over when actual damage occurred precludes summary judgment that a legal malpractice claim is barred by the six-year limitations period.

Ellison v. Schenck, Price, Smith & King · filed 1995-03-16

We are satisfied that the question of when actual damage occurred is a genuine issue of material fact and therefore summary judgment was improvidently granted.

The six-year period for a legal malpractice claim begins when the client knows or should know that the attorney's negligence caused injury.

DIXON TICONDEROGA COMPANY v. ESTATE OF WILLIAM F. O'CONNOR · filed 2001-04-23

We believe that Dixon was on notice that O'Connor's alleged malpractice may have caused it harm by that date, and therefore hold that Dixon's malpractice action against O'Connor and the Schumann firm accrued by October 21, 1985, and, consequently, expired October 21, 1991, six years later.

The six-year limitations period for legal malpractice does not begin merely because a client hires counsel to defend a lawsuit; the client must have suffered actual damages.

Sullivan v. Aslanides · filed 2005-01-06

A claim of legal malpractice is subject to a six-year period of limitations. ... We do not think either Grunwald or Dixon stand for the proposition that when an individual hires an attorney as a result of actions by another attorney, the statute of limitations begins to run on a malpractice action against the original attorney.

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

WIEBEL VS. MORRIS, DOWNING & SHERRED, LLP (L-0681-14, SUSSEX COUNTY AND STATEWIDE) · filed 2018-12-06

Therefore, plaintiff's complaint would be timely under New Jersey's six-year statute of limitations for attorney malpractice, N.J.S.A. 2A:14-1, but would be untimely under California's one-year statute of limitations, Cal. Civ. Proc. Code § 340.6(a).

The six-year limitations period for a legal-malpractice claim begins when the attorney’s negligence causes actual damage.

Olds v. Donnelly · filed 1997-07-16

Olds’s legal-malpractice claim against Donnelly did not accrue for either statute-of-limitations or entire-controversy purposes until the dismissal with prejudice of the medical-malpractice action in March 1991.

The six-year period for a legal malpractice claim may be postponed under the discovery rule until the client knows or reasonably should know the essential facts of the claim.

HAGER VS. HOWARD D. POPPER, ESQ.(L-1477-13, MORRIS COUNTY AND STATEWIDE) · filed 2017-11-17

Here, the critical date for evaluating the level of plaintiff's knowledge of such "essential" facts to support a legal malpractice claim is May 30, 2007, i.e., six years before he filed his complaint.

The six-year limitations period for legal malpractice claims does not begin until the client suffers actual damage and discovers, or reasonably should discover, the facts supporting the claim.

CCM PROPERTIES, LLC VS. THOMAS C. PIEPER (L-1690-16, MONMOUTH COUNTY AND STATEWIDE) · filed 2018-06-20

Pieper's alleged misadvice to close title — not discovered until plaintiffs received the phase I report — suffices to save the malpractice claim from dismissal.

Section 2A:14-1's six-year limitations period barred an amendment asserting new claims after the plaintiff learned of the alleged legal malpractice.

THORPE VS. JUSTIN SWIDLER, ESQ. (L-0274-17, MERCER COUNTY AND STATEWIDE) · filed 2019-05-07

Plaintiff learned in December 2010 that summary judgment was granted to the defendants in the employment discrimination action; she stated she read the transcript of the summary judgment hearing in early 2011. Therefore, the statute of limitations expired, at the latest, in early 2017. Plaintiff did not move to amend her complaint until July 2017, after the expiration of the statute of limitations.

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

WARREN v. STEVEN J. KAY ASSOCIATES · filed 2020-01-17

The statute of limitations under New York law is three years, see C.P.L.R. § 214; under New Jersey law, it is six years, see N.J. Stat. Ann. § 2A:14-1. Because this action was filed on June 13, 2019, any claim against the Steven Kaye firm that arose prior to June 13, 2016 (NY) or, at the earliest, June 13, 2013 (NJ) is time- barred.

The six-year period for a legal malpractice claim runs from accrual, which requires actual damage and discovery, or reasonably possible discovery, of the facts essential to the claim.

JONES VS. ANDREW VIOLA, ESQ. (L-4285-16, CAMDEN COUNTY AND STATEWIDE) · filed 2020-02-27

It is undisputed that the applicable statute of limitations for legal malpractice cases in this State is the generous six-year period set forth in N.J.S.A. 2A:14-1. That statute requires a legal malpractice action to commence within six years from the accrual of the cause of action. ... Based on our objective review of the record, appellant's cause of action for legal malpractice did not accrue until 2012 when the Family Part denied her motion to extend the LDA alimony period beyond the nine years specified in the divorce judgment.

Section 2A:14-1 requires a professional malpractice claim to be filed within six years after the cause of action accrues.

DANIEL MOTLEY VS. RALPH L. FINELLI VS. STEVEN LISA (L-0834-16, ESSEX COUNTY AND STATEWIDE) · filed 2019-07-16

As the court correctly noted, N.J.S.A. 2A:14-1 governs the time in which plaintiff's claims against defendant for professional malpractice must be filed. The statute provides that the action must be filed within six years after the cause of action accrued.

The six-year limitations period applies to professional negligence claims against an insurance broker.

COTO VS. CUNNINGHAM CONSTRUCTION COMPANY, LLC (L-0648-17, UNION COUNTY AND STATEWIDE) · filed 2020-03-06

Because plaintiff alleges professional negligence against the broker, those claims are subject to a six-year statute of limitations.

Section 2A:14-1 gives a plaintiff six years to bring a legal malpractice claim, beginning when the plaintiff suffers damages and discovers, or reasonably should discover, the facts essential to the claim.

BASS v. PURDUE PHARMA L.P. · filed 2021-12-06

Additionally, legal malpractice claims are governed by the six-year statute of limitations established in N.J. Stat. Ann. § 2A:14-1. ... This six-year statute of limitation period begins to run when a plaintiff first suffers damages and then discovers — or through the use of reasonable diligence should have discovered — the facts essential to their malpractice claim. ... In other words, February 27, 2013 is the date the statute of limitations for his claim against Ms. Austin began to run, and his claims against Ms. Austin are now barred by the statute of limitations.

The six-year period for a legal malpractice claim begins when the client suffers actual damage and discovers, or reasonably should discover, the facts essential to the claim.

HUNNELL v. ALIDA MCKEON (L-4179-19, MONMOUTH COUNTY AND STATEWIDE) · filed 2022-08-11

The statute of limitations for a legal malpractice claim is six years, N.J.S.A. 2A:14-1, but, under the applicable discovery rule, the cause of action accrues when "the client suffers actual damage and discovers, or through the use of reasonable diligence should discover, the facts essential to the malpractice claim," Rogers v. Cape May Cnty. Off. of the Pub. Def., 208 N.J. 414, 422 (2011) (quoting Grunwald v. Bronkesh, 131 N.J. 483, 494 (1993)). ... Based on McKeon's allegation that Hunnell's negligent representation was the proximate cause of her losses, McKeon averred sufficient facts to state a legal malpractice claim within the limitations period.

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

REAVES v. MONMOUTH UNIVERSITY · filed 2022-12-15

As the Court currently construes Plaintiffs claims, ... and six years for the legal malpractice claim. (N.J.S.A. 2A:14-1).

Section 2A:14-1 sets a six-year limitations period for legal malpractice actions.

KAMDEM-OUAFFO, PHD v. COLGATE PALMOLIVE COMPANY · filed 2023-10-31

However, “New Jersey’s statute of limitations for legal malpractice [ ] actions is six years.” Yerkes v. Weiss, No. 17-cv-2493, 2018 WL 1558146, at *5 (D.N.J. Mar. 29, 2018) (citing N.J.S.A. 2A:14-1); see also ECF No. 45 at 10. Therefore, Plaintiff’s fraud and malpractice claims must be dismissed.

Section 2A:14-1's six-year limitations period applies to a legal malpractice claim for the loss of recovery in a personal injury action.

Fuschetti v. Bierman · filed 1974-04-30

The former statute applies to any other "tortious injury to the rights of another * * * or for recovery upon a contractual claim or liability * * *." ... Such is not the case here where defendant is charged with having caused plaintiff the loss of recovery from an action which happens to be for a personal injury.

Section 2A:14-1 gives a plaintiff six years to bring a legal malpractice claim for pecuniary loss caused by an attorney's negligence.

Carney v. Finn · filed 1976-12-06

Clearly, we do not deal here with a personal injury claim but rather an assertion that an attorney engaged for a particular purpose was negligent in the handling of it, resulting in pecuniary loss to appellant. Such a claim comes under N.J.S.A. 2A:14-1 (the six-year statute) and is therefore not barred.

Professional negligence claims have a six-year limitations period; a plaintiff invoking the discovery rule must show ordinary diligence in discovering the claim.

Cosmopolitan Shipping CO., Inc. v. Continental Insurance Company · filed 2021-07-27

To show that the claim is timely under the six-year New Jersey statute of limitations, Plaintiff must show that, in the exercise of ordinary diligence, it did not and could not have discovered its claim against Marsh until at least 2012 or later. Plaintiff has not sustained its burden.

Section 2A:14-1 gives plaintiffs six years to bring a legal malpractice action.

Sysol v. Sanchez · filed 2025-10-31

Legal malpractice actions, which derive from the tort of negligence, are subject to a six-year statute of limitations.

Section 2A:14-1 gives legal malpractice claims six years from accrual to be filed.

O'Boyle v. Braverman · filed 2009-07-15

New Jersey, on the other hand, allows six years from the accrual of the cause of action. McGrogan v. Till, 167 N.J. 414, 771 A.2d 1187, 1194 (2001) (holding that legal malpractice actions are governed by the six year statute of limitations contained in N.J.S.A. 2A:14-1).

Section 2A:14-1 gives six years to bring a contractual claim on an instrument that is not under seal.

Beneficial Finance Co. v. Dixon · filed 1974-10-16

If the instrument is not under seal, N.J.S.A. 2A:14-1, the six-year statute, controls; if the instrument is under seal, N.J.S.A. 2A:14-4, the 16-year statute, controls. ... Testing of the note and security agreement here in dispute against the above criteria results in the conclusion that it is indeed an instrument under seal, controlled not by the six-year statute, but by the 16-year statute.

Section 2A:14-1 applies a six-year limitations period to an action on a promissory demand note.

Ligran, Inc. v. Medlawtel, Inc. · filed 1980-06-20

With respect to the appeal of Butkus, it is first clear that the general six-year statute of limitations prescribed by N.J.S.A. 2A:14-1 applies.

Section 2A:14-1 gives a judgment creditor six years to sue on an insurance policy under the insured’s rights.

Casey v. Selected Risks Ins. Co. · filed 1980-10-10

The present action on the policy is one in contract and is thus governed by the general six-year statute of limitations for contracts set forth in N.J.S.A. 2A:14-1.

Section 2A:14-1's six-year limit for contractual claims applies to a teacher's claim for statutory military service salary credit because the credit is an implied term of the teaching contract.

Lavin v. Hackensack Bd. of Ed. · filed 1981-03-09

Hence the credit is directly related to compensation and thus, under Miller, enforcement of it is a contractual claim subject to N.J.S.A. 2A:14-1.

The six-year period for contractual claims does not apply to a public employee’s statutory benefit that is separate from the employment contract.

Lavin v. Hackensack Bd. of Ed. · filed 1982-06-24

The statute of limitations applicable to a "recovery upon a contractual claim or liability" is six years. N.J.S.A. 2A:14-1 (emphasis added). ... Accordingly, the payment should be considered as a statutory entitlement, rather than as an element of the employment contract. That being so, the statute of limitations is inapplicable.