N.J. Stat. Ann. § 2A:14-1

Section 2A:14-1 allows six years to seek payment of a cashier's check, subject to defenses against payment.

Santos v. First Nat'l State Bk. of NJ · filed 1982-08-26

This is consistent with our conclusion that a cashier's check need not be presented promptly for payment but may be presented at any time during the six year statute of limitations, N.J.S.A. 2A:14-1, subject to defenses against payment that may be asserted.

Section 2A:14-1 provides a six-year limitations period for contract actions, which governs an independent federal claim for breach of a union constitution when borrowed as federal law.

Papianni v. International Ass'n of Bridge, Structural & Ornamental Iron Workers · filed 1985-12-10

Standing independent of plaintiff’s claim created by the federal labor law, as it does, plaintiff’s contract claim is subject to the borrowed New Jersey statute of limitations of six years for contract actions. N.J.Stat.Ann. 2A:14-1.

Section 2A:14-1 supplies a six-year limitations period for an independent claim for breach of a union constitution.

Papianni v. INTERN. ASS'N OF B., S. & OI WORKERS · filed 1985-12-19

Standing independent of plaintiff's claim created by the federal labor law, as it does, plaintiff's contract claim is subject to the borrowed New Jersey statute of limitations of six years for contract actions. N.J.Stat. Ann. 2A:14-1.

Section 2A:14-1 imposes a six-year limitations period on contract claims; the indemnity claim here accrued when Ashland failed to respond to the demand.

Southland Corp. v. Ashland Oil, Inc. · filed 1988-10-06

Any cause of action based on breach of the contract’s indemnity provision accrued at the time Ashland failed to respond to Southland’s claim — in 1980. As such, it is now time-barred under New Jersey’s six-year statute of limitation for claims based on contract. N.J.Stat.Ann. § 2A:14-1 (West 1987).

The six-year limitations period for a claim on an assignment of life insurance proceeds begins when the policy becomes payable at the insured’s death, even if a suit on the underlying loan is already barred.

In re Franklin · filed 1989-03-24

Similarly, the statute of limitations on the assignment of Franklin’s insurance policy began to run only after the policy became payable on the death of the insured in 1987.

Section 2A:14-1 gives common-law fraud claims a six-year limitations period that begins when the fraud is discovered or could have been discovered through reasonable diligence.

Center Cadillac, Inc. v. Bank Leumi Trust Co. · filed 1992-04-13

New Jersey’s statute of limitations for common-law fraud is six years. N.J.S.A. 2A:14-1. The limitations period for fraud begins to run when the fraud is discovered or could have been discovered through reasonable diligence. ... Plaintiffs’ common law fraud claim is therefore dismissed under New Jersey’s six year statute of limitations.

Section 2A:14-1 provides a six-year limitations period for contract actions that governs claims for delinquent employee benefit fund contributions under the LMRA and ERISA.

Hotel Employees & Restaurant Employees International Union Welfare Fund v. Pub of New Jersey · filed 1990-09-07

For the foregoing reasons, we hold that N.J.Rev.Stat. § 2A:14-1, the six-year statute of limitations period for contract actions, governs the instant action.

Payments on current invoices do not bring older invoices within Section 2A:14-1's running-account exception without an acknowledgment of the larger unpaid balance.

Deluxe Sales v. Hyundai Engineering & Construction Co. · filed 1992-03-06

This exception clearly does not apply here. In this case, the record reflects that payments were applied to the most current accounts rather than to the oldest outstanding invoices.

Section 2A:14-1 gives six years to bring a common law implied warranty claim, whether the claim sounds in contract or tort.

TERRACE CONDO. ASSO. v. Midlantic Nat. Bank · filed 1993-07-19

The applicable limitation period with respect to plaintiff's cause of action is the usual six year limitation period provided by N.J.S.A. 2A:14-1. That statute states that "every action at law... for any tortious injury to real or personal property ... or for recovery upon a contractual claim or liability, express or implied, not under seal ... shall be commenced within 6 years next after the cause of such action shall have accrued." Thus, whether the breach of implied warranty is deemed contractual or tortious in nature, the six year statute of limitations applies.

Section 2A:14-1 requires a breach of contract claim to be filed within six years after it accrues.

Windsor Card Shops, Inc. v. Hallmark Cards, Inc. · filed 1997-02-20

In New Jersey, a breach of contract claim must be filed within six years after the cause of action has accrued.

Section 2A:14-1 provides a six-year limitations period for recovery on a contractual claim or liability.

Asset Recovery Co., LLC v. Jackson · filed 2002-05-13

New Jersey’s statute of limitations on “recovery upon a contractual claim or liability,” is six years, N.J. Stat. § 2A:14-1, as compared to California’s four-year statute, California Civil Procedure Code § 337 for written contracts, or two-year statute under § 339 for oral contracts. Thus, step one in the three-step approach is satisfied because these laws do differ.

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

Baer v. Chase · 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.

Section 2A:14-1 provides a six-year limitations period for claims sounding in restitution, unjust enrichment, or quantum meruit.

Iwanowa v. Ford Motor Co. · filed 1999-10-28

The statute of limitations in New Jersey for claims sounding in restitution/unjust enrichment or quantum meruit is six years.

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

Ramada Franchise Systems, Inc. v. Capitol View II Ltd. Partnership Venture · filed 2001-02-21

New Jersey’s statute of limitations, however, bars any claims that accrued before March 1994, leaving only two remaining: (1) the alleged overpayments that accrued after March 1994; and (2) the changed designation of the property in 1996.

Section 2A:14-1 gives a creditor six years to sue on a demand note governed by the pre-1995 UCC, measured from the note's execution and delivery.

Sarasota-Coolidge Equities II, LLC v. S. Rotondi and Sons, Inc. · filed 2001-04-12

Here, under N.J.S.A. 2A:14-1 and N.J.S.A. 12A:3-122(1)(b), defendant's right to rely upon the statute of limitations defense did not become a vested right until March 12, 1997, that is, six years after the note's execution and delivery to Suburban on March 11, 1991.

Section 2A:14-1 supplies a six-year limitations period for ERISA benefits and estoppel claims.

Gashlin v. Prudential Insurance Co. of America Retirement System for the United States Employees & Special Agents · filed 2003-09-04

New Jersey applies a 6-year statute of limitations period to contract actions. ... As such, to assert timely benefits and estoppel claims, Mr. Gashlin must have filed a suit against Prudential within 6-years of the date on which the claims accrued.

The six-year limitations period applies to claims arising from home construction when the transaction primarily involves building services and the supply of materials is incidental.

DiIorio v. Structural Stone & Brick · filed 2004-04-02

Based upon our careful consideration of the defendant's arguments in light of the record and the applicable law, we agree that plaintiffs' claims are governed by the six year statute of limitations; however, in our view the transaction was primarily one for the professional services of a builder in which Structural Stone supplied stone incidental to the contract for the construction of residential premises.

Section 2A:14-1 gives a party six years to bring a claim for rescission.

34 LABEL STREET ASSOCIATES VS. RICHARD CECERE (L-0496-12, ESSEX COUNTY AND STATEWIDE) (CONSOLIDATED) · filed 2017-12-04

The applicable statute of limitations for claims of rescission is six years. N.J.S.A. 2A:14-1. Cecere breached the Ground Lease in 2007, and 34 Label obtained a judgment in March 2011. After Cecere refused to pay that judgment, 34 Label filed its claim for rescission in 2012. All of that took place within the applicable six years.

Section 2A:14-1 gives parties six years from accrual to bring claims to void lease agreements or recover rent paid under them; annual rent payments do not restart that period.

PATHWAY CONDOMINIUM ASSOCIATION, INC. VS. OCEAN GROVE CAMP MEETING ASSOCIATION OF THE UNITED METHODIST CHURCH (L-0313-17 · filed 2018-06-28

The statute of limitations applicable to all of those claims is set forth in N.J.S.A. 2A:14-1.

Section 2A:14-1’s six-year limitations period does not apply to a contract predominantly for goods with incidental installation services.

Meyers v. Henderson Construction Co. · filed 1977-01-27

The issue to be resolved is whether the plaintiff's action on a contract is barred by the four-year limitation period of N.J.S.A. 12A:2-725 or whether the six year limitation period of N.J.S.A. 2A:14-1 is applicable. ... The contract is, therefore, governed by the U.C.C., and the four-year limitation period of N.J.S.A. 12A:2-725 is properly applicable.

Section 2A:14-1 provides a six-year limitations period for a claim alleging breach of an oral agreement.

RA Intile Realty Co. v. Raho · filed 1992-07-02

Since plaintiff's claim for breach of the alleged oral agreement of December 21, 1987 is not barred by the six year statute of limitations contained in N.J.S.A. 2A:14-1 and since amendments to pleadings are to be granted freely in the interests of justice pursuant to R. 4:9-1, the court will sua sponte permit the first count of the complaint to be deemed amended to assert a claim by plaintiff for breach of the alleged oral agreement of December 21, 1987 and to include allegations that such alleged oral agreement was confirmed in a writing which was received by the Raho defendants within five days of the oral agreement in compliance with N.J.S.A. 25:1-9 and was never repudiated in writing by the Raho defendants.

Section 2A:14-1 provides a six-year limitations period for contract actions, which applies to analogous ERISA benefits claims.

Kapp v. Trucking Employees of North Jersey Welfare Fund, Inc.-Pension Fund · filed 2011-05-04

In this context, we apply New Jersey‟s six-year limitations period that governs contract actions. Connell, 118 F.3d at 156 n.4; N.J. Stat. Ann. § 2A:14-1.

Section 2A:14-1 bars breach of contract and unjust enrichment claims filed more than six years after they accrue.

Rubinsky v. Zayat · filed 2017-01-04

As for Rubinsky’s accrual argument, for substantially the reasons provided by the District Court in its opinions accompanying its two orders, we agree with the District Court that his claims accrued no later than 2005. Because the six-year limitations period expired well before Rubinsky filed his complaint in 2014, the District Court correctly concluded that his claims were time-barred and that Zayat was entitled to summary judgment.

Section 2A:14-1 gives a party six years to bring a contract claim for a share of property sale proceeds under a matrimonial settlement agreement.

AVRAMOVICH VS. LISA GARSON (FM-09-2293-11, HUDSON COUNTY AND STATEWIDE) · filed 2018-12-11

However, defendant's claim that plaintiff did not share the proceeds after surreptitiously selling 50 North Walnut Street, after the MSA was signed but before the divorce was finalized, is a contract claim, with a six-year statute of limitations. N.J.S.A. 2A:14-1.

The six-year limitations period applies to unjust enrichment claims, even though they are equitable in nature.

Penn National Insurance v. North River Insurance · filed 2019-07-30

First, unjust enrichment is a quasi-contractual claim, and while equitable in nature, those claims are subject to the six-year statute of limitations.

The six-year limitations period does not bar an unjust enrichment claim based on the defendant’s current use of molds made years earlier.

INTECH POWERCORE CORPORATION v. ALBERT HANDTMANN ELTEKA GMBH & CO. KG · filed 2021-03-24

As an initial matter, and contrary to Defendant’s assertion, Plaintiff predicates its unjust enrichment claim on Defendant’s current, not past, use of the molds in its business dealings with Fanuc. ... Thus, Plaintiff’s claim is not barred by the statute of limitations.

Section 2A:14-1 gives a claimant six years to bring an unjust enrichment claim; the discovery rule does not extend that period when the claimant already knew of the claim.

DEVINO VS. ANNA ULASHKEVICH (L-2054-19, MONMOUTH COUNTY AND STATEWIDE) · filed 2021-12-08

Here, the discovery rule provides no refuge for plaintiff from the six-year limitations period in N.J.S.A. 2A:14-1 that bars his cause of action; the undisputed facts establish he had actual knowledge of the claim more than six years prior to the filing of his complaint.

Section 2A:14-1 provides a six-year limitations period for a promissory estoppel claim based on a promise to waive lien rights.

Tocci Building Corporation v. Trane U.S. Inc. · filed 2025-11-14

The court concludes that the six-year limitations period applies. ... Courts interpreting New Jersey law have consistently applied the six-year limitations period in N.J.S.A. 2A:14-1 to promissory estoppel claims.

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

TFI Tutti LLC v. Sono America, Inc. · filed 2025-12-19

New Jersey provides six years for contract claims, so Delaware’s shorter three-year period governs.

Section 2A:14-1 requires a breach of contract claim to be filed within six years after it accrues; the period began when the plaintiff knew of the alleged breach.

Fitzig v. Quick Cooling & Heating, LLC · filed 2026-05-22

Thus, he failed to seek relief within the six-year statute of limitations, as required by N.J.S.A. 2A:14- 1, resulting in his complaint being time-barred.

Section 2A:14-1 provides a six-year limitations period for ordinary breach-of-contract actions.

GONZALES v. ETHICON CORPORATION, INC. · filed 2019-09-11

This statute, which applies to contracts for sale, is not to be confused with the six-year statute of limitations that applies in ordinary breach of contract actions.

Section 2A:14-1 provides a six-year limitations period for ordinary breach of contract actions but excludes contracts for sale governed by section 12A:2-725.

MARTINEZ v. ETHICON INC. · filed 2019-09-12

This statute, which applies to contracts for sale, is not to be confused with the six-year statute of limitations that applies in ordinary breach of contract actions. See N.J. Stat. Ann. § 2A:14-1 (“This section shall not apply to any action for breach of any contract for sale governed by section 12A:2- 725 of the New Jersey Statutes”).

Section 2A:14-1 sets a six-year limitations period for contract claims, which parties may waive by expressly agreeing to a shorter period.

Eagle Fire v. FIRST INDEM. INS. · filed 1995-03-28

Similarly, New Jersey courts have routinely upheld contractual limitations that waive by express agreement the six-year statute of limitations.

The six-year limitations period for contractual claims permits a prevailing party to enforce an arbitration award after the ninety-day period for summary confirmation expires.

Granville B. Taylor, Jr. v. Ford Motor Company, and Local 980, Uaw (United Automobile, Aerospace and Agriculture Impleme · filed 1983-03-30

We hold, therefore, that a prevailing party in an arbitration proceeding who has not confirmed an award within the statutory limitations period under NJ.Stat.Ann. 2A:24-7 has not lost the right to enforce that award given the six year limitations period for contractual claims found in NJ. Stat.Ann. 2A:14-1.

Section 2A:14-1 provides a six-year limitations period for contract claims but does not prohibit a reasonable contractual agreement to a shorter period.

Ribeira & Lourenco v. Jackson Health · filed 1989-02-16

Additionally, we emphasize that the one-year limitation period contained in the bond is not against public policy or prohibited by New Jersey law simply because N.J.S.A. 2A:14-1 provides for a six-year statute of limitations upon a contractual claim.

The six-year limitations period for contract actions applies to a common-law plenary action to confirm an arbitration award.

POLICEMAN'S BENEVOLENT ASSOCIATION, LOCAL 292 v. Bor. of N. Haledon · filed 1999-06-08

Otherwise, the prevailing party retains the common-law right to seek confirmation in a plenary proceeding within the six-year statute of limitations applicable to contracts. N.J.S.A. 2A:14-1.

Section 2A:14-1 sets a six-year limitations period but allows parties to contract for a shorter filing period.

Mirra v. Holland America Line · filed 2000-05-19

N.J.S.A. 2A:14-1 sets forth the statute of limitations in New Jersey, but does not prohibit parties to a contract from stipulating to a shorter time period.

Section 2A:14-1 sets a six-year maximum for contract claims; parties may agree to a shorter period unless a statute forbids it.

Brian E. Harris, M.D. v. Provident Life and Accident Insurance Company · filed 2008-04-30

A statute of limitations is a maximum, not a minimum. See N.J. Stat. Ann. § 2A:14-1 (“Every action . . . for recovery upon a contractual claim . . . shall be commenced within 6 years next after the cause of any such action shall have accrued”). (Emphasis added). ... Parties are free, however, to contract for a shorter period, unless a statute specifically forbids them from doing so.

Section 2A:14-1 provides a six-year limitations period for New Jersey breach of contract claims, though parties may agree to a shorter period if it is not manifestly unreasonable.

Klimowicz v. Unum Life Insurance · filed 2008-10-10

The statute of limitations for a breach of contract claim in New Jersey is six years. N.J. Stat. Ann. § 2A:14-1. Parties may, however, contract for a shorter limitation period, as long as the contractual period is not manifestly unreasonable.

The six-year limitations period for contract claims may be shortened by a reasonable agreement between the parties.

Satellites v. Home2US Communications, Inc. · filed 2014-03-28

It is well settled that parties may contractually limit the time for bringing claims, despite a statute of limitations to the contrary.

A partial settlement payment alone does not restart the six-year limitations period on a time-barred contractual debt.

Genova v. Total Card, Inc. · filed 2016-06-08

Under New Jersey law, however, the Court concludes that the settlement payments solicited in the Letter would not restart the statute of limitations on the MBC Debt.

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

DEUTSCHE BANK NATIONAL TRUST COMPANY, ETC. VS. AVERY PATRICK (L-0289-17, MIDDLESEX COUNTY AND STATEWIDE) · filed 2018-12-18

The statute of limitations for trespass is six years. See N.J.S.A. 2A:14-1.

Section 2A:14-1’s six-year limit applies to a contractual right to reinstate a complaint under a consent order; a waiver covering the complaint’s claims does not waive the limit for enforcing the order.

BLANCHARD VS. EDWARD D. CRITCHFIELD, SR. (L-0806-08, CAPE MAY COUNTY AND STATEWIDE) · filed 2020-01-21

The judge correctly found that the statute of limitations applied and barred the reinstatement of plaintiffs' amended complaint. ... The parties never agreed to waive the six-year statute of limitations with regard to the terms of the consent order.

Section 2A:14-1 provides a six-year period for contract claims, but parties may agree to a shorter limitations period.

SPINA v. METROPOLITAN LIFE INSURANCE COMPANY (METLIFE) · filed 2021-06-21

Accordingly, the Court finds that the New Jersey statutory limitations period is not a minimum requirement, and the Policy’s limitations period is applicable here regardless of which interpretation is adopted.

Section 2A:14-1 provides six years to bring a contract claim, but a reasonable insurance policy term may shorten the time to sue to one year.

LAROSA VS. ALLSTATE NEW JERSEY INSURANCE COMPANY (L-1201-18, OCEAN COUNTY AND STATEWIDE) · filed 2021-07-30

The one-year time limit was established under the terms of the insurance policy, which reduced the six-year period within which suit could be brought under the statute of limitations. See N.J.S.A. 2A:14-1. ... As we have noted, suit limitation provisions reducing the time to bring suit otherwise afforded under the statute of limitations are reasonable, common, and enforceable.

Section 2A:14-1 sets a six-year limitations period for contract actions, which insurance policies may shorten.

BERKZUP RIDGEFIELD, LLC v. AMERICAN BANKERS INSURANCE COMPANY OF FLORIDA · filed 2021-11-01

Under New Jersey law, contract actions are subject to a six-year statute of limitations. See N.J.S.A. § 2A:14-1. ... Here, the terms of both the Travelers and the American Bankers policies shortened that statutory six-year period to two years and one year, respectively.

Section 2A:14-1(a) bars a contractual claim or arbitration request made more than six years after the cause of action accrued.

East Coast Wall Systems, LLC v. Tkt Construction Co., Inc. · filed 2024-03-07(a)

Under these circumstances, we decline to conclude the judge erred in finding the SOL under N.J.S.A. 2A:14-1 barred EC's belated request for arbitration.

Section 2A:14-1 gives an insured six years to demand arbitration under an uninsured motorist endorsement.

Selected Risks Ins. Co. v. Dierolf · filed 1975-12-19

As such, the statute of limitations established by N.J.S.A. 2A:14-1 governs. Since defendant made his demand for arbitration as provided in the endorsement and since that demand was made well within the six-year period, defendant Dierolf's access to arbitration is not barred by N.J.S.A. 2A:14-1.

Section 2A:14-1 provides a six-year limitations period for suits on insurance policies, including uninsured motorist endorsements, absent a contrary policy provision or express statute.

Walkowitz v. Royal Globe Insurance Company · filed 1977-05-05

Finally, we hold that plaintiff's claim under the UM endorsement is not barred by our two-year statute of limitations. Absent a provision in the insurance policy or an express statute to the contrary, the statute of limitations applicable to a suit on a policy of insurance, including the UM endorsement attached thereto, is six years. N.J.S.A. 2A:14-1.

Section 2A:14-1's six-year limitations period would apply to an insured's contractual claim for PIP benefits if the no-fault law had no specific limitations provision.

Ochs v. Federal Ins. Co. · filed 1980-12-23

If the no-fault law had contained no special limitations provision, we are satisfied that the general six-year statute of limitations of N.J.S.A. 2A:14-1 would apply in respect of direct claims by an insured against his carrier for the PIP benefits provided for in the policy of insurance.

Section 2A:14-1’s six-year limitations period does not govern actions against the Unsatisfied Claim and Judgment Fund to recover PIP benefits.

Garcia v. Snedeker · filed 1985-02-25

We also reject plaintiff's alternative argument that the right to recover PIP benefits from the Fund is grounded upon the theory of quasi -contract and, thus, the six-year statute of limitations mandated by N.J.S.A. 2A:14-1 is controlling.

The six-year limitations period does not govern a coinsurer contribution claim that must be resolved by inter-company arbitration or agreement.

Ideal Mut. Ins. Co. v. Royal Globe Ins. Co. · filed 1986-06-20

Although we do not ordinarily concern ourselves with issues not raised by the parties, the statute permits of no way to determine whether plaintiff's right to relief is time-barred except in terms of equitable principles applicable to arbitration. In this context neither the two year nor the six year statute governs.

Section 2A:14-1 bars an insurance contract claim filed more than six years after the insured discovered or should have discovered the property damage.

Haardt v. Farmer's Mutual Fire Insurance · filed 1992-07-07

Unlike the situation in Royal Indemnity, the Haardts discovered or should have discovered the alleged property damage resulting from the windstorm immediately after its occurrence on June 18, 1983. Since the complaint was filed on January 19, 1991, over six years after the Haardt’s cause of action accrued, it is barred pursuant to N.J.S.A. 2A:14-1.

The six-year limitations period does not begin when an environmental agreement leaves an insured’s liability contingent on the discovery of contamination.

Federal Insurance Ex Rel. Associated Aviation Underwriters v. Purex Industries, Inc. · filed 1997-06-27

The insurers’ claim that the liability of Purex was finally determined by the signing of the ACO is unpersuasive. The ACO merely required testing of environmental conditions and remediation of contamination that might be discovered. In other words, liability was not finally determined at this point because any liability was contingent upon the discovery of contamination.

Section 2A:14-1 gives an insurer six years to assert a limitations defense after a policy’s no-action clause is triggered; the insurer cannot assert that defense before then.

Crest-Foam Corp. v. Aetna Ins. Co. · filed 1999-04-29

In essence, the "no action" clause may prevent or delay an action for indemnification, but it also prevents the assertion of the statute of limitations defense to a declaratory judgment action before it is triggered and for six years thereafter.

Section 2A:14-1 sets a six-year limit for contract claims, including insurance suits, unless the policy or another statute provides a different limit.

Gahnney v. State Farm Insurance · filed 1999-07-27

N.J.S.A. 2A:14-1, states, in pertinent part, as follows: “recovery upon a contractual claim or liability, shall be commenced within 6 years next after the cause of any such action shall have accrued.” Therefore, “[a]bsent a provision in the insurance policy or an express statute to the contrary, the statute of limitations applicable to a suit on a policy of insurance” is six years.

The six-year limitations period applies to uninsured motorist claims; when the other driver's insurer becomes insolvent, the claim accrues when insolvency is declared.

Golden v. GMAC INS. CO. · filed 2008-06-23

The six-year statute of limitations, N.J.S.A. 2A:14-1, is applicable to UM claims. ... Accordingly, plaintiff's UM claim did not accrue until the order was issued declaring Security insolvent and enjoining her from pursuing and collecting a claim against Security based upon its insureds' liability.

The six-year limitations period does not bar a fee-disgorgement claim on summary judgment when the record does not establish when the claimants knew or had reason to know the overall fee was excessive.

Higgins v. Thurber · filed 2010-04-21

The judge also granted summary judgment dismissing the fee-disgorgement claim based on the six-year statute of limitations, N.J.S.A. 2A:14-1. ... Because the record is unclear as to the commencement of the limitation period on this claim, we reverse that part of the order under review as well.

Section 2A:14-1 applies a six-year limitations period to breach of contract claims, including claims under a title insurance policy.

COLE-PARKER VS. FIDELITY NATIONAL TITLE INSURANCE COMPANY (L-4276-15, MONMOUTH COUNTY AND STATEWIDE) · filed 2018-07-09

These uncontested facts show plaintiff's complaint against Fidelity filed on November 17, 2015 is barred by the six-year statute of limitations applicable to all claims based on breach of contract.

The six-year limitations period for UM/UIM claims runs from the accident date, and this accrual rule applies prospectively.

Green v. Selective Insurance Co. of America · filed 1996-06-12

In keeping with that philosophy, we believe that the statute of limitations on UM/UIM claims should run from the date of an accident. ... Because we are resolving for the first time the date on which the statute of limitations on UM/UIM claims begins to run, it is in the interest of "fairness and justice" to apply this holding prospectively.

Section 2A:14-1’s six-year limitations period bars an insurance-policy claim based on an alleged miscalculation more than six years before suit.

SPALTER v. PROTECTIVE LIFE INSURANCE COMPANY · filed 2022-11-28

Plaintiff sets forth an additional argument disputing Defendant’s calculation of the amount needed to take the certificate out of grace status, but grounds the argument on Defendant committing this alleged miscalculation in August 2009, (D.E. 17-7 at 7–10), which means that the statute of limitations of six years would bar this claim.

Section 2A:14-1’s six-year limitations period for insurance contract claims may be shortened by the policy’s terms.

APTSIAURI v. CSAA GENERAL INSURANCE COMPANY · filed 2024-10-24

First, it is well settled under New Jersey law that the terms of an insurance contract may shorten the statute of limitations period. Gutierrez v. Am. Bankers Ins. Co. of Fl., No. 22-3551, 2024 WL 3439447, at *2 (N.J. Super. Ct. App. Div. July 17, 2024) (finding, on appeal of a lower court’s motion to dismiss decision, that “there is a six-year statute of limitations for claims brought pursuant to an insurance contract” but that such period “may be shortened by the terms of [the] insurance contract” (citing N.J. Stat. Ann. § 2A:14-1)).

The six-year period for UIM claims against insurers begins on the accident date; equitable estoppel requires proof that the insurer's conduct caused the late filing.

Chenel v. Allstate Insurance Company · filed 2025-10-09(a)

It is well-established that the six-year statute of limitations established in N.J.S.A. 2A:14-1(a) applies to UIM claims against insurance carriers and begins to run from the date of the accident. ... Plaintiff produced no proof defendant's conduct caused him to refrain from filing a timely complaint. Equitable relief was not warranted.

Section 2A:14-1 gives professional negligence and breach-of-contract claims a six-year limitations period; equitable tolling requires diligence in pursuing a timely claim.

Binder v. Price Waterhouse & Co., LLP · filed 2007-05-30

Actions in professional negligence and breach of contract have six-year statutes of limitations. N.J.S.A. 2A:14-1. ... In light of this holding, equitable tolling, not substantial compliance, is the proper standard to apply in this case, a proposition that does not work to plaintiff's legal disadvantage. ... In addition, absent a showing of trickery, diligence by Binder, or that the interest of justice demands the complaint be deemed timely filed, equitable tolling cannot be applied to save his claim, given that such relief is to be utilized sparingly and here Binder waited, at a minimum, eight months to file his state claim following dismissal of the federal action and then did not pursue it.

A contract claim filed within the six-year period may still face a laches defense when the circumstances warrant it.

Chance v. McCann · filed 2009-03-11

The Estate filed suit against McCann within the six-year period of limitations for an action on a contract. N.J.S.A. 2A:14-1. ... Consequently, we hold that this is the rare case in which an equitable defense of laches should be considered, despite the fact that the case was timely filed under the applicable statute of limitations.

A contract complaint filed within the six-year limitations period may be restored after dismissal even if that period has since expired.

ASHI-GTO v. Irvington Pediatrics · filed 2010-07-15

Upon a showing of good cause, an order dismissing a matter may be set aside and the case restored; that the statute of limitations may have run in the interim is not a bar. ... Plaintiff's initial complaint having been filed within the period of limitations, there was no statutory bar to restoration.

Section 2A:14-1 gives CFA actions a six-year limitations period, but equitable recoupment permits an otherwise untimely claim to be raised as a defense.

THE BANK OF NEW YORK MELLON, ETC. VS. JOHN KINGSBURY (F-012351-15, OCEAN COUNTY AND STATEWIDE) · filed 2018-07-13

The trial court also found the statute of limitations bars defendant's CFA defense. However, we find the doctrine of equitable recoupment saves the defense. We agree the statute of limitations bars defendant from pursuing an action under the CFA. The statute of limitations for the CFA is six years. N.J.S.A. 2A:14-1; Trinity Church v. Lawson- Bell, 394 N.J. Super. 159, 170 (App. Div. 2007) (citing Mirra v. Holland Am. Line, 331 N.J. Super. 86, 90-91 (App. Div. 2000)).

The six-year limitations period does not bar a recoupment defense when the main action is timely.

WELLS FARGO BANK, N.A. VS. NARESH G. GIDWANI (F-024030-14, MIDDLESEX COUNTY AND STATEWIDE) · filed 2018-08-03

We agree defendants' recoupment claim was not time barred.

The six-year limitations period for a UIM claim is not equitably tolled when the insured shows no reliance on the insurer's conduct and lets the period expire without demanding arbitration.

KENNETH DOCTORS VS. NEW JERSEY MANUFACTURERS INSURANCE COMPANY (L-4991-18, MIDDLESEX COUNTY AND STATEWIDE) · filed 2020-04-03

There are no facts in this case to support an equitable tolling of the statute of limitations' application.

Section 2A:14-1 gives a predatory lending claim under the CFA a six-year limitations period, but equitable recoupment permits an otherwise stale claim to be raised defensively.

DEUTSCHE BANK NATIONAL TRUST COMPANY, ETC. VS. JEFFREY MERZ (F-030746-15, BERGEN COUNTY AND STATEWIDE) · filed 2019-10-08

We also acknowledge that a predatory lending claim under the CFA is governed by a six-year statute of limitations, N.J.S.A. 2A:14-1, which expired two years before defendant filed his answer raising the CFA as a defense. However, defendant's CFA claim is preserved under the doctrine of equitable recoupment, which allows a defendant to assert an otherwise stale CFA claim and avoid the statute of limitations, where, as here, the defendant uses the claim "'as a shield by way of counterclaim'" instead of "'as a sword . . . .'" Nester v. O'Donnell, 301 N.J. Super. 198, 208 (App. Div. 1997) (quoting Midlantic Nat'l Bank v. Georgian Ltd., 233 N.J. Super. 621, 625 (Law Div. 1989)).

Section 2A:14-1’s six-year limitations period applies to actions at law and does not bar an equitable claim to correct a deed.

LOTT VS. BOROUGH OF ROSELLE (C-000131-18, UNION COUNTY AND STATEWIDE) · filed 2020-12-28

The statute of limitations contained in N.J.S.A. 2A:14-1 is inapplicable to plaintiff's equitable claim for the corrected deed, and defendants' reliance on the statute as its solitary defense to plaintiff's claim is misplaced and should have been rejected by the trial court.

The six-year limitations period barred claims that accrued in 1988, and equitable tolling did not apply without evidence that defendants prevented plaintiffs from asserting their rights.

1530 OWNERS CORP. VS. AMERICANA ASSOCIATES (C-000181-19 AND C-000281-19, BERGEN COUNTY AND STATEWIDE) (CONSOLIDATED) · filed 2021-10-14

Moreover, the record is devoid of evidence showing plaintiffs were deprived of asserting their rights by defendants in an "extraordinary way" and the expanse of time that has passed since plaintiffs' claims accrued in 1988 impels us to conclude they did not timely assert their rights. Plaintiffs' claims exceeded the statute of limitations under N.J.S.A. 2A:14-1 and N.J.S.A 2A:14-7.

The six-year limitations period may be equitably tolled when a court invites an amended complaint without setting a deadline and the plaintiffs promptly seek to amend.

HP HOLDING LLC v. RED ROOF INNS, INC. · filed 2025-02-26

Under the specific facts of this case, it is clear to the Court that the absence here of a specific deadline by which to amend when the Court clearly identified the deficiencies that needed attention represents an extraordinary circumstance that absent tolling would prevent Plaintiffs from pursuing their claims and correcting the various deficiencies the Court invited them to remedy. And notably, the Plaintiffs here moved in a timely fashion. The Court accordingly declines to disrupt Plaintiffs’ acceptance of this Court’s explicit invitation to cure the deficiencies identified with the previous complaint and finds the claims equitably tolled.

Section 2A:14-1’s six-year period supplies the analogous limitations period for Lanham Act laches, measured from when the plaintiff knew or should have known of its claim.

NEWBORN BROS. CO., INC. v. ALBION ENGINEERING COMPANY · filed 2021-04-05

In order to determine which party bears the burden of proving or disproving the laches defense in this case, the Court must resolve whether Newborn knew or should have known about its Lanham Act claim more than six years before Newborn filed this action (i.e., before May 18, 2006), to which the Court concludes in the negative.

An action to recover on an official bond is a contractual claim subject to the six-year limitations period in § 2A:14-1.

County of Hudson v. Janiszewski · filed 2007-11-05

Because different principles of law attach to the claim asserted under the Bonds than those asserted against the other Defendants, the Court must apply the statute of limitations appropriate for a breach of contract claim, rather than the four-year statute of limitations applicable in a RICO or NJRICO claim. Indeed, New Jersey statutory law imposes a six-year statute of limitations on an action “for recovery upon a contractual claim or liability....” N.J.S.A. 2A:14-1.

Section 2A:14-1 provides a six-year limitations period for contract claims, but it does not apply when the plaintiff has no contract with the defendant.

Bamigbade v. State Farm Mutual Automobile Insurance · filed 2010-08-09

Bamigbade’s reliance on a contract claim against State Farm (subject to a six-year statute of limitations period, see N.J. Stat. Ann. § 2A:14-1) is misplaced, as he never entered into any insurance policy or contract with State Farm.

Section 2A:14-1 provides a six-year limitations period for breach-of-contract claims that applies to analogous ERISA nonfiduciary claims.

Sturgis v. Mattel, Inc. · filed 2007-11-29

Here, New Jersey is the only state with any connection to this action and the parties agree that these claims are analogous to a breach of contract claim, which has a six-year statute of limitations. ... Accordingly, Plaintiffs claims for PIP and Health and Welfare Benefits accrued in 1997 and this action, filed more than six years later, is not timely.

Section 2A:14-1 gives unjust enrichment claims six years from accrual; whether the discovery rule delays accrual may require fact discovery.

Sensient Colors, Inc. v. Kohnstamm · filed 2008-03-10

The applicable statute of limitations in New Jersey, N.J.S.A. § 2A:14-1, provides that claims for unjust enrichment must be commenced within six years after the cause of action has accrued. ... Whether the equities favor the application of the strict statute of limitations or the discovery rule can be better assessed after fact discovery. Accordingly, Defendants’ Motion to Dismiss Sensient’s claim of unjust enrichment is denied.

Section 2A:14-1 gives express contractual indemnification claims a six-year limitations period under New Jersey law.

Travelers Indem. Co. v. Dammann & Co., Inc. · filed 2010-02-05

Under New Jersey Law, express contractual indemnification claims are subject to a six-year statute of limitations.

The six-year limitations period makes a debt unenforceable in court but does not extinguish the debt.

Huertas v. Galaxy Asset Management · filed 2011-04-11

We agree with the District Court, however, that, under New Jersey law, Huertas‟s debt obligation is not extinguished by the expiration of the statute of limitations, even though the debt is ultimately unenforceable in a court of law.

Section 2A:14-1 provides a six-year limitations period for contractual claims, which the court applied to an ERISA benefits claim.

Raymond v. Barry Callebaut USA LLC · filed 2013-01-15

Under New Jersey‟s six-year limitations period, Raymond had until 2003 to file her § 1132(a)(1)(B) claim; however, she did not do so until March 7, 2011, when she first filed her complaint in Superior Court.

Section 2A:14-1 limits liability for past condominium assessments to six years.

Highpoint at Lakewood Condominium Association, Inc. v. The · filed 2015-08-14

Although Lakewood is potentially subject to assessments, its liability for past assessments may be barred by principles of waiver or laches; in any event, Lakewood's liability is limited by the statute of limitations.

The six-year limitations period runs separately for each missed installment payment absent anticipatory repudiation.

In the Matter of the Estate of Solomon Z. Balk · filed 2016-05-12

The Estate is entitled to all payments which were due from the six years prior to the motion's filing date of June 2, 2014; ... therefore, we find the judge's conclusion that the Estate is "entitled to collect on each of the installment payments that was due and owing by Roseman on and after June 3, 2008" to be correct.

Section 2A:14-1 provides a six-year limitations period for a customer's breach-of-contract claim against its bank for failing to protect the customer's interests.

Kraftsman Container Corp. v. United Ctys. Trust Co. · filed 1979-06-19

Therefore the claims on these older checks are not barred by § 4-406(4), but are subject to the six-year statute of limitation, N.J.S.A. 2A:14-1. Summary judgment on those checks must therefore be denied, and these items included in the total claim, subject to the standards set forth infra.

Section 2A:14-1 sets a general six-year limitations period for actions on a promissory note.

Govan v. Trade Bank & Trust Co. · filed 1970-03-17

N.J.S.A. 2A:14-1 establishes a general six-year statute of limitations for actions on a promissory note.

Section 2A:14-1 gives a party six years to bring a contract action; the court measured that period from the promissory note default.

DVL, INC. v. Mutnick · filed 2000-07-06

Under New Jersey law, the statute of limitations for contract actions is six years. ... In sum, there is no basis for restarting the statute of limitations and DVL’s claim against Mutnick therefore is time-barred.

Section 2A:14-1's six-year limitations period bars a predatory-lending CFA defense first asserted more than six years after the borrower executed the note.

U.S. BANK, N.A., ETC. VS. LUBICA VILCEKOVA (F-047074-14, HUDSON COUNTY AND STATEWIDE) · filed 2017-10-13

Defendant executed the note on July 27, 2007, and did not assert the CFA defense until June 15, 2015, when she filed her answer. The defense, therefore, is time-barred by the six-year statute of limitations.

Section 2A:14-1 gives a plaintiff six years to sue for unpaid services and bars recovery for work performed before that period.

KIMERLING & WISDOM, LLC VS. MARIA T. SCARIATI (L-3027-14, HUDSON COUNTY AND STATEWIDE) · filed 2017-11-14

Therefore, plaintiff was barred from recovering any funds for work performed before July 8, 2008, which was the first day of the six-year statute of limitations period, and the judge erred by applying N.J.S.A. 2A:14-24 to the facts of this case.

Section 2A:14-1 gives a party six years to sue for breach of a settlement agreement.

L.A., ETC. VS. SOUTH ORANGE-MAPLEWOOD BOARD OF EDUCATION (L-8454-16, ESSEX COUNTY AND STATEWIDE) · filed 2019-02-27

Plaintiff filed her complaint in 2016, well beyond the six-year period of limitations under N.J.S.A. 2A:14-1.

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

PERRY v. NATIONAL CREDIT UNION ADMINISTRATION · filed 2019-10-28

Under New Jersey law, the applicable statute of limitations period for generic breach of contract claims is six (6) years.

The six-year limitations period for a breach of contract claim begins when the plaintiff has an enforceable right to sue.

MARVIN T. BOYD, M.D. VS. RENAL CENTER OF PASSAIC (C-000144-17, PASSAIC COUNTY AND STATEWIDE) · filed 2020-08-11

He failed to seek the requested relief within six years, as required by N.J.S.A. 2A:14 -1, and his complaint is therefore time-barred.

The six-year limitations period applies to claims for breach of the implied covenant of good faith and fair dealing.

FLINT GROUP PACKAGING INKS NORTH AMERICA CORP. v. FOX INDUSTRIES INC. · filed 2020-10-20

Thus, the applicable statute of limitations would only bar Flint’s implied covenant claim if it accrued before May 25, 2010. Because Flint’s implied-covenant claim is based on conduct that occurred years after 2010, the Court finds that the statute of limitations does not bar Flint’s implied-covenant claim.

Section 2A:14-1 gives six years to bring a contract claim from accrual; an attorney fee claim accrues when legal services end or the attorney-client relationship ends, whichever occurs first.

SOBEL AND BROWN, PC VS. THOMAS HOXIE (L-4418-18, BERGEN COUNTY AND STATEWIDE) · filed 2021-01-04

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

Section 2A:14-1 requires contractual claims to be brought within six years.

LONERGAN VS. TOWNSHIP OF SCOTCH PLAINS (L-3700-16, UNION COUNTY AND STATEWIDE) · filed 2019-05-29

In accordance with N.J.S.A. 2A:14-1, any action for "recovery upon a contractual claim or liability, express or implied," must be commenced within six years.

Section 2A:14-1 requires a contractual claim to be commenced within six years.

GINSBERG VS. DAVID BISTRICER (C-000113-98, ESSEX COUNTY AND STATEWIDE) · filed 2019-06-11

In accordance with N.J.S.A. 2A:14-1, any action for "recovery upon a contractual claim or liability, express or implied," must be commenced within six years.

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

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

New Jersey’s six-year limitations period is appropriate instead.

Section 2A:14-1 sets a six-year limitations period for breach-of-contract claims under New Jersey law.

POE v. DRIVER HISTORY SALES CORP. · filed 2021-12-15

Finally, the Court notes that Poe’s claim for breach of contract is not barred by the statute of limitations. Under New Jersey law, a claim for breach of contract must be asserted within the six-year statute of limitations period as prescribed by statute. See Thakar v. JFK Med. Ctr., 2007 WL 1498816, at *1 (N.J. Super. Ct. App. Div. May 24, 2007) (citing N.J. Stat. Ann. § 2A:14-1). Here, the alleged sale which gave rise to Poe’s claim that he is entitled to proceeds from the sale under the Consulting Agreement occurred in November 2014; Poe filed the initial Complaint on October 16, 2020.

Section 2A:14-1 gives a plaintiff six years from accrual to bring a breach of contract claim.

GORDON v. NICE SYSTEMS, INC. · filed 2022-12-23

Under New Jersey law, a claim for breach of contract is subject to a six-year statute of limitations. N.J.S.A. 2A:14-1. ... Therefore, a claim for commission on any October 2011 or earlier Booking is time-barred.

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

LOCKHART v. DORRANCE PUBLISHING COMPANY, INC. · filed 2023-01-11

Under New Jersey law, the statute of limitations for breach of contract claims is six years.

Section 2A:14-1 requires contract claims to be brought within six years after the cause of action accrues.

MEDICAL INDICATORS, INC. VS. MOSHE LAVID (C-000032-16, MERCER COUNTY AND STATEWIDE) · filed 2021-10-04

We also find no error in the trial court's order that defendant's counterclaims were barred by the six-year statute of limitations for contracts. "In New Jersey, causes of action based on contractual claims must be brought within six years 'after the cause of any such action shall have accrued.'" Crest-Foam Corp. v. Aetna Ins. Co., 320 N.J. Super. 509, 517 (App. Div. 1999) (quoting N.J.S.A. 2A:14-1).

Section 2A:14-1 gives a contractual claim six years from accrual to be filed.

SANGHANI v. RAJESHKUMAR M. PATEL (L-4558-20, HUDSON COUNTY AND STATEWIDE) · filed 2022-08-05

The critical threshold question before us is whether plaintiffs' complaint was filed within the applicable statute of limitations. The general statute of limitations for a contractual claim is six years after accrual. N.J.S.A. 2A:14-1.

Section 2A:14-1’s six-year limitations period for contract claims does not apply to claims that do not assert a contract cause of action.

SPECIAL POLICE ORGANIZATION v. CITY OF NEWARK (L-7121-19, ESSEX COUNTY AND STATEWIDE) · filed 2022-07-25

For example, in Point II of their merits brief, plaintiffs argue the court erred by relying on the two-year statute of limitations in N.J.S.A. 2A:14-2(a) because "N.J.S.A. 2A:14-1 has a [six]-year statute for contracts," and the RICO statute, "has a [five to ten] year statute of limitations." The argument ... borders on the frivolous because counts one through seven of the complaint do not assert either contract or RICO claims.

Section 2A:14-1 generally gives six years to bring a contract claim, but a contract claim brought by the State is governed by a ten-year period.

STATE OF NEW JERSEY v. JAMES GENCARELLI (L-1413-01, MERCER COUNTY AND STATEWIDE) · filed 2022-10-20

Thus, neither the six-year statute of limitations under N.J.S.A. 2A:14-1, on which defendant incorrectly relies, nor the ten-year statute of limitations under N.J.S.A. 2A:14-1.2 had run, and the State timely filed the complaint within the applicable statute of limitations.

Section 2A:14-1 applies a six-year limitations period to a declaratory judgment claim based on a contract.

Zhejiang Topoint Photovoltaic Co., Ltd. v. Chen · filed 2023-03-30

Because the declaratory judgment claim relates to a contract, it is subject to a six-year statute of limitations under New Jersey law.

Section 2A:14-1(a) supplies the six-year limitations period for a contractual claim analogous to an ERISA plan reformation counterclaim.

LUCIANO v. TEACHERS INSURANCE AND ANNUITY ASSOCIATION OF AMERICA - COLLEGE RETIREMENT EQUITIES FUND (TIAA-CREF) · filed 2023-07-26(a)

Here, the parties and the Court agree that New Jersey’s six-year statute of limitations for “recovery upon a contractual claim or liability, express or implied” would govern the instant claim. N.J.S.A. § 2A:14-1(a).

Section 2A:14-1 gives a plaintiff six years from the breach to bring a New Jersey breach of contract claim.

SIZMUR v. AG · filed 2023-09-28

In New Jersey, a breach of contract claim is subject to a six-year statute of limitations. N.J. Stat. Ann. § 2A:14-1. That limitations period begins to run on the date of the breach. ... By their own pleading, that alleged breach occurred when they entered into the Lease in March 2016—more than six years before commencing this action. [Compl. ¶ 2.] As pled, their breach of contract claim is untimely.

The six-year limitations period for a pay-when-able loan claim begins when the creditor learns the debtor is able to pay.

Karvellas v. Sweeney · filed 2024-11-19(a)

Judge Ostuni then concluded the six-year statute of limitations under N.J.S.A. 2A:14-1(a) did not bar plaintiff's complaint because the Third Loan was a valid contract presented as a "pay-when-able" loan. The judge found a breach of contract action based on a pay-when-able loan commences when a plaintiff learns a defendant is able to pay. ... Because we agree with Judge Ostuni that plaintiff's complaint was timely filed, we need not consider defendants' argument that the judge erred in applying the doctrine of equitable estoppel to bar their statute of limitations defense.

Section 2A:14-1(a) gives a party six years to sue for a missed contractual payment, with a separate claim accruing for each missed payment.

Morris Bellifemine, M.D., Pa v. Meadowlands Hospital Medical Center, Mha, LLC · filed 2025-01-13(a)

N.J.S.A. 2A:14-1 serves as a basis for partial summary judgment in defendants' favor for any cause of action accruing prior to November 2014. However, each pay period missed from November 2014 until the sale of the hospital in December 2017 represents a ... cause of action accruing within the six-year timeframe, and the statute of limitations does not serve as a basis to dismiss these portions of plaintiff's claim.

A contract claim on a loan payable on demand accrues when the loan is made and must be filed within six years.

Tjn Development, LLC v. Schoner · filed 2025-12-24(a)

Since the loans are payable on demand, plaintiffs' cause of action accrued, under N.J.S.A. 2A:14-1(a), at the time each loan was made to defendant.