Statute Annotations › New Jersey › N.J. Stat. Ann. § 2A:14-2

N.J. Stat. Ann. § 2A:14-2

Actions for injury to person: the cases that interpreted this section

Jurisdiction
New Jersey
Case notes
479
Cited in passing
205
Citing cases indexed
769
Case dates
1956–2026
Screened through
2026-05-29
Courts' treatment: live
No reviewed case has held this section invalid, preempted, superseded or repealed.
This reflects what the reviewed cases said, not legislative action: a later amendment or repeal by the legislature would not appear here unless a reviewed case discussed it.

684 citing cases reviewed of 769 in the citation index: 479 interpreted the section (annotated below), 205 cited it only in passing. Cases filed after 2026-05-29 may not have been reviewed yet.

Have a situation under N.J. Stat. Ann. § 2A:14-2?

These notes show how courts have ruled. Ask about your specific facts and see which of these rulings apply, with citations you can check.

Two-year period for personal injury claims

Section 2A:14-2 provides a two-year limitations period measured from accrual of a personal injury claim.

Smith v. Estate of Kelly · filed 2001-08-08

The applicable limitation period is two years from accrual of the cause of action, [4] N.J.S.A. 2A:14-2, or from age eighteen if accrual occurred during minority.
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Section 2A:14-2 sets a two-year limitations period for personal injury claims, which the court applied to the § 1983 and battery claims.

Rolax v. Whitman · filed 2001-11-01

The New Jersey statute of limitations for claims asserting personal injuries is two years. N.J.S.A. § 2A:14-2. Thus, Rolax’s § 1983 claims and the common law battery claim contained in Count Five are governed by the same two-year statute of limitations.
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Section 2A:14-2 supplies a two-year limitations period for personal injury claims, including claims under 42 U.S.C. §§ 1983 and 1985.

Freeman v. State · filed 2002-01-23

Plaintiffs do not contest that their actions, brought under the Civil Rights Act, 42 U.S.C. § 1983 and 1985, which are essentially actions in tort based upon either infringement of liberty and property rights (§ 1983) or conspiracy on the part of government to deprive a person or class of persons of equal protection of the law (§ 1985), are governed by our two-year statute of limitations applicable to personal injury torts, N.J.S.A. 2A:14-2.
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Section 2A:14-2 imposes a two-year limitations period; later discovery of evidence irrelevant to the claims does not prevent the claims from being time barred.

Druz v. Boro of Manasquan · filed 2002-11-15

The Magistrate Judge found that Druz’s complaint was barred by the two year statute of limitations. See N.J.S.A. 2A:14-2. Druz argues that his claims should not be barred by the statute of limitations because he was unaware, until June 16, 1998, of the destruction of certain audio cassette tapes. However, as the Magistrate Judge concluded, the tapes were not relevant to Druz’ constitutional challenges. Thus, Druz’s claims are time barred.
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Section 2A:14-2 provides a two-year limitations period for personal injury claims, including § 1983 malicious prosecution claims filed in New Jersey.

Backof v. New Jersey State Police · filed 2004-02-13

The relevant statute of limitations under New Jersey law is the two-year statute of limitations applicable to personal injury ... torts: N.J.S.A. § 2A:14-2. ... A § 1983 claim filed in New Jersey and based on malicious prosecution is timely if it is filed within two years of the dismissal of criminal charges.
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Section 2A:14-2 sets a two-year limitations period for personal injury claims, which applies to § 1983 claims filed in New Jersey.

Padilla v. Township of Cherry Hill · filed 2004-10-05

Because New Jersey’s statute of limitations for personal injury is two years, see N.J.S.A. 2A:14-2,3 Rivera’s claims are subject to a two-year statute of limitations.
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Section 2A:14-2 sets a two-year limitations period for personal injury tort claims.

Jama v. United States Immigration & Naturalization Service · filed 2004-11-10

The New Jersey statute of limitations period for tort claims for personal injury is two years, N.J.S.A. 2A:14-2. ... In the present case, with the exception of any ATCA claim or any RFRA claim, each claim is subject to the two year statute of limitations.
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Section 2A:14-2 sets a two-year limitations period for personal injury claims against a school; minority tolls the period, and the discovery rule may affect when a claim accrues.

Dm v. River Dell Reg. High School · filed 2004-12-23

As the court recognized in its written decision, the two-year statute of limitations set forth in N.J.S.A. 2A:14-2, tolled only for the period of the plaintiffs' minority, applies to these claims.
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Section 2A:14-2 supplies the two-year limitations period for personal injury actions, including claims brought under 42 U.S.C. § 1983 in New Jersey.

Gibson v. NJ Dept Law & Pub · filed 2005-06-14

An action brought under 42 U.S.C. § 1983 is subject to the ... state statute of limitations that governs actions for personal injury. Cito v. Bridgewater Township Police Dep’t, 892 F.2d 23, 25 (3d Cir. 1989). “In New Jersey that statute is N.J.S.A. 2A: 14-2, which provides that an action for an injury to the person caused by a wrongful act, neglect, or default, must be convened within two years of accrual of the cause of action.”
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Section 2A:14-2 supplies the two-year limitations period for personal-injury actions, including § 1983 claims brought in New Jersey.

Gibson v. Superintendent of New Jersey Department of Law & Public Safety-Division of State Police · filed 2005-06-14

“In New Jersey that statute is N.J.S.A. 2A: 14-2, which provides that an action for an injury to the person caused by a wrongful act, neglect, or default, must be convened within two years of accrual of the cause of action.” ... In the case before us, the arrest, trial and other multiple alleged illegal acts all occurred more than two years before this suit was brought, and therefore all would be barred by the two-year statute of limitations.
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Section 2A:14-2 sets a two-year limitations period for a survival action, measured from the injury or other loss.

Vassiliu v. Daimler Chrysler Corp. · filed 2000-12-18

Each action has a separate statute of limitations. N.J.S.A. 2A:31-3 (wrongful death action must be brought within 2 years after the decedent's death); N.J.S.A. 2A:14-2 and -23.1 (survival action must be brought within 2 years after the injury or other loss occurred, except that if an action for injuries or other losses incurred by the decedent was not barred as of the date of or less than 6 months prior to his death, the limitations period is extended for at least 6 months after his death).
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Section 2A:14-2 supplies New Jersey’s two-year limitations period for personal injury actions, which governs § 1983 claims brought in New Jersey.

Akinola v. Clifton · filed 2006-03-15

Accordingly, New Jersey’s two-year limitations period for personal injury actions governs Akinola’s claims. See Brown v. Foley, 810 F.2d 55, 56 (3d Cir. 1987); see also N.J. Stat. Ann. § 2A:14-2.
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Section 2A:14-2's two-year limit barred the counterclaims for negligence, misrepresentation and fraud, even if the period was tolled during an earlier action.

Menorah Chapels v. Needle · filed 2006-06-08

We find, however, that those portions of Needle's counterclaim asserting causes of action premised upon negligence, misrepresentation and fraud were properly dismissed. None was timely, even if we deem the applicable period of limitations to have been tolled during the pendency of Menorah Chapel's initial action. N.J.S.A. 2A:14-2.
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Section 2A:14-2 sets a two-year limitations period for personal injury actions; a minor’s time to file begins at age eighteen under Section 2A:14-21.

Phillips v. Gelpke · filed 2007-05-17

Although the statute of limitations for actions "caused by the wrongful act, neglect or default of any person within this state" is two years "next after the cause of any such action shall have accrued," N.J.S.A. 2A:14-2, a minor's cause of action does not accrue until he or she reaches the age of eighteen. N.J.S.A. 2A:14-21; see also Green v. Auerbach Chevrolet Corp., 127 N.J. 591, 598, 606 A. 2d 1093 (1992). Thus, plaintiff had until her twentieth birthday to file her complaint. She filed when she was nineteen and, therefore, her complaint was timely.
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Section 2A:14-2 provides a two-year limitations period for Bivens claims and intentional infliction of emotional distress claims against individual federal officials.

Curbison v. United States Government of New Jersey · filed 2007-06-27

His constitutional claims under Bivens as well as his intentional infliction of emotional distress claims against the individual federal officials were both subject to New Jersey’s two-year statute of limitations for personal injury causes of action.
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Section 2A:14-2(a) supplies a two-year limitations period for constitutional and tort claims arising from personal injury.

Amadi v. FCI Fort Dix Health Services · filed 2007-11-30(a)

Specifically, Amadi’s constitutional and tort claims against the Individual Defendants were barred by the applicable, two-year statute of limitations. See, e.g., N.J. Stat. Ann. § 2A:14-2(a); Napier v. Thirty or More Unidentified Fed. Agents, 855 F.2d 1080, 1087 & n.3 (3d Cir. 1988).
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Section 2A:14-2(a) imposes a two-year limitations period on the public-policy and negligent-supervision claims at issue.

Roa v. Roa · filed 2008-07-07(a)

Defendants further contended that plaintiffs' public policy claims in the third count also must be dismissed because they were preempted by the LAD, ... or was otherwise subject to the two-year statute of limitations contained in N.J.S.A. 2A:14-2(a). ... Moreover, the waived claims are deficient as a matter of law and time-barred for the reasons urged by defendants, which we cited above.
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Section 2A:14-2 gives plaintiffs two years to bring negligence and emotional distress claims after those claims accrue.

Campanello v. Port Auth. of New York & New Jersey · filed 2008-12-19

Count V alleges negligence. Count VII alleges intentional infliction of emotional distress. Count VIII alleges negligent infliction of emotional distress. All three causes of action are subject to a two year statute of limitations.
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Section 2A:14-2(a) sets a two-year limitations period for personal injury claims; the court applied that period to § 1983 and Title VI claims.

Yip v. Union Cty College · filed 2009-02-03(a)

A two-year statute of limitations applies to Yip’s constitutional claims under 42 U.S.C. § 1983, as well as his claim under Title VI, 42 U.S.C. § 2000d.1 ... N.J.S.A.§ 2A:14- 2(a) (two-year statute of limitations applies to personal injury claims).
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Section 2A:14-2 provides a two-year limitations period that barred claims filed more than two years after the alleged wrong.

Juan v. Sanchez · filed 2009-06-05

Also, as the District Court concluded, the applicable two year statute of limitations, see Wilson v. Garcia, 471 U.S. 261, 278-80 (1985); Cito v. Bridgewater Township Police Dep’t, 892 F.2d 23, 24 (3d Cir. 1989); Cardena v. Massey, 269 F.3d 251, 255 (3d Cir. 2001) (citing Goodman v. Lukens Steel Co., 482 U.S. 652, 662 (1987)); N.J. Stat. Ann. § 2A:14-2; Fraser v. Bovino, 721 A.2d 20, 26 (N.J. Super. Ct. 1998), expired before Juan filed his federal complaint.
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Section 2A:14-2 supplies the two-year limitations period for § 1983 claims arising in New Jersey.

Chen v. Township of Fairfield · filed 2009-12-02

Under New Jersey law, the relevant statute of limitations is two years. See N.J. Stat. Ann. § 2A:14-2.
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Section 2A:14-2’s two-year limitations period applies to claims for harassment, intentional infliction of emotional distress, discrimination, retaliation, conspiracy, and obstruction of justice.

Agcaoili v. Thayer · filed 2010-02-16

The District Court correctly concluded that New Jersey’s two-year limitations period for personal injury claims applies to Agcaoili’s claims for harassment, intentional infliction of emotional distress, discrimination, retaliation, conspiracy, and obstruction of justice.
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Section 2A:14-2 sets a two-year limitations period for New Jersey personal injury claims, including claims under 42 U.S.C. § 1983.

Dique v. New Jersey State Police · filed 2010-05-06

New Jersey, as the parties agree, is the applicable state here; it mandates a two- year statute of limitations period for personal-injury torts. N.J. Stat. Ann. § 2A:14–2 (West 2004). Thus, a section 1983 claim arising in New Jersey has a two-year statute of limitations.
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Section 2A:14-2 provides a two-year limitations period for New Jersey § 1983 claims; an amendment adding a defendant after that period is time-barred when neither the discovery rule nor equitable tolling applies.

Bustamante v. Borough of Paramus · filed 2010-05-07

In this case, the judge did not mistakenly exercise his discretion by denying the motion because the amendment seeking to add Von Schalscha was time-barred by the statute of limitations. See N.J.S.A. 2A:14-2; Cowell v. Palmer Twp., 263 F. 3d 286, 291 (3d Cir.2001) (noting § 1983 actions in New Jersey are governed by a two-year statute of limitations).
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Section 2A:14-2 sets a two-year limitations period for personal injury claims, which the court applied to a Bivens claim filed in New Jersey.

Brown v. Camden Cty Counsel · filed 2010-05-13

In New Jersey, the statute of limitations for personal injury claims is two years.
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Section 2A:14-2 provides a two-year limitations period for personal injury actions that applies to these federal and state civil rights damages claims.

Major Tours, Inc. v. Colorel · filed 2010-06-22

The parties agree that New Jersey’s two-year statute of limitations on personal injury actions, N.J. Stat. Ann. § 2A:14-2, applies to the federal and state civil rights acts claims for damages against State Defendants in their personal capacities. The first complaint in this action was filed on June 15, 2005, which is therefore the earliest possible date to which the contents of the current complaint could relate back.
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Section 2A:14-2 gives a claimant two years from accrual to file a personal injury claim.

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

Therefore, Bamigbade had two years from the time his cause of action accrued to file his complaint. See N.J. Stat. Ann. § 2A:14-2.
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Section 2A:14-2 sets a two-year limitations period for personal injury actions, which supplies the limitations period for a § 1983 claim arising in New Jersey.

McPherson v. United States · filed 2010-09-02

We need not determine whether the District Court chose correctly, as New Jersey and Pennsylvania both have a two-year limitations period for personal injury actions. See N.J. Stat. Ann. § 2A:14-2; 42 Pa. Cons. Stat. § 5524. Because McPherson’s claim accrued no later than January 12, 1996, the statutes of limitations of New Jersey and Pennsylvania required McPherson to have filed his suit by January 12, 1998.
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Section 2A:14-2(a) sets a two-year limitations period for personal injury actions, which the court applied to an ADA claim.

Abulkhair v. PPI/Time Zero Inc · filed 2010-10-27(a)

In New Jersey, the statute of limitations for personal injury actions is two years.
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Section 2A:14-2(a) provides the two-year limitations period applied to claims under LMRDA §§ 101(a)(1) and 101(a)(2).

Wiggins v. United Food & Commercial Workers Union, Local 56 · filed 2006-03-20(a)

There is no dispute that the applicable statute of limitations governing Plaintiffs claims under §§ 101(a)(1) and 101(a)(2) of Title I of the Labor-Management Reporting and Disclosure Act of 1959 is two years. ... For these reasons, the Court holds that period of limitations began to run, at the latest, on May 17, 2002. Because Plaintiffs Complaint was not filed until over two years later, the Complaint is untimely.
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Section 2A:14-2 provides a two-year limitations period for personal injury claims, including discrimination claims under the NJLAD.

Hanani v. New Jersey Department of Environmental Protection · filed 2006-11-09

Personal injury claims based upon discrimination are subject to the two-year statute of limitations set forth in N.J. Stat. Ann. § 2A:14-2.
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Section 2A:14-2 supplies the two-year limitations period for Section 1983 claims arising in New Jersey.

Myers v. County of Somerset · filed 2007-06-11

In New Jersey, the relevant statute of limitations is two years from the date that the cause of action accrued.
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Section 2A:14-2 provides a two-year limitations period for personal injury claims, barring § 1983 retaliation claims based on acts more than two years before suit.

LaPosta v. Borough of Roseland · filed 2009-02-03

In dismissing portions of LaPosta’s § 1983 claim on statute of limitations grounds, the District Court explained that the New Jersey statute of limitations for personal injury claims provides for a two-year statute of limitations. See Cito v. Bridgewater Twp. Police Dep’t, 892 F.2d 23, 25 (3d Cir. 1989); N.J.S.A. 2A:14-2. ... Accordingly, we affirm the District Court’s order insofar as it dismissed LaPosta’s § 1983 claim with regard to pre-December 6, 2004 retaliation.
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Section 2A:14-2 sets a two-year limitations period for personal injury actions that applies to § 1983 civil rights claims in New Jersey.

Wright v. Drug Enforcement Agency · filed 2009-11-30

We have held that New Jersey’s two-year limitations period on personal injury actions, N.J.S.A. 2A:14-2, applies to civil rights claims under § 1983. Cito v. Bridgewater Township Police Dep’t, 892 F.2d 23, 25 (3d Cir.1989). Thus, the complaint, filed in August 2007, was untimely with respect to the July and October 2004 articles.
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Section 2A:14-2 bars a negligence claim filed more than two years after the alleged conduct.

Ayala v. ASSURED LENDING CORPORATION · filed 2011-06-27

Plaintiffs’ negligence claim is barred by the statute of limitations. The alleged conduct occurred in late 2006 and the Complaint was not filed until May 29, 2009, exceeding the two-year statute of limitations. N.J. Stat. Ann. § 2A:14-2.
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Section 2A:14-2 sets a two-year limitations period for personal injury claims, including assault.

Pittman v. Metuchen Police Department · filed 2011-08-02

In New Jersey, the statute of limitation for personal injury claims, including assault, is two years. N.J. Stat. Ann. § 2A:14-2; Cito v. Bridgewater Township Police Dep’t, 892 F.2d 23, 25 (3d Cir. 1989).
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Section 2A:14-2 provides a two-year limitations period for damages claims based on racial profiling.

Major Tours, Inc. v. Colorel · filed 2011-10-11

The parties agree that New Jersey’s two-year statute of limitations on personal injury actions, N.J. Stat. Ann. § 2A:14-2, applies to all of Plaintiffs’ damages claims based on racial profiling.
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Section 2A:14-2 provides a two-year limitations period for a breach-of-fiduciary-duty claim akin to a personal-injury action.

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

Having so assumed, we agree with the District Court that breach of this kind of “fiduciary relationship” is akin to a personal-injury action, which (as above) is governed by a two-year statute of limitations.
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Section 2A:14-2 sets a two-year limitations period for personal injury claims.

Rogers v. Maretz · filed 2013-05-14

As noted by the Magistrate Judge, Rogers’ proposed claims regarding incidents from 2006 would not withstand a motion to dismiss, as they are barred by New Jersey’s two-year statute of limitations for personal injury claims.
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Section 2A:14-2(a) gives plaintiffs two years from accrual to file a personal injury action, including a § 1983 claim arising in New Jersey.

Vickers v. Childs · filed 2013-07-03(a)

In New Jersey, plaintiffs must file personal injury actions within two years of the accrual date. N.J. Stat. Ann. § 2A:14-2(a) (West 2004). Therefore a § 1983 claim arising in New Jersey will be time-barred if more than two years has passed since its accrual.
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Section 2A:14-2 sets a two-year limitations period for personal injury claims.

McGill v. Evanina · filed 2013-10-10

In New Jersey, the statute of limitations for personal injury claims is two years. N.J.S.A. 2A:14-2.
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Section 2A:14-2 imposes a two-year limitations period on claims arising from personal injury caused by wrongful acts or neglect, even when framed as violations of statutory rights.

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

However, N.J.S.A. § 2A:14-2 explicitly provides for a two-year statute of limitations for wrongful acts, neglect, or default — which are exactly the harms Plaintiff alleges in her description of her claims as for “neglect and mistreatment.” ... Upon reconsideration, the Court finds that the two-year statute of limitations applies to the outstanding NHRRRA claim as well, and Defendants are therefore entitled to dismissal of the Second Count as a matter of law.
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Section 2A:14-2 sets a two-year period for filing a personal injury action.

Giannakopoulos v. Mid State Mall · filed 2014-12-31

MidState and Maser stand in different procedural postures, because plaintiff filed a timely complaint against MidState, but filed the complaint against Maser more than a year beyond the two-year statute of limitations.
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Section 2A:14-2 provides a two-year limitations period for personal injury claims, including claims brought under § 1983 in New Jersey.

Atkinson v. Middlesex County · filed 2015-04-21

Atkinson’s claims were all based on § 1983 and state-law torts, all of which have two-year statutes of limitations.
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Section 2A:14-2(a) time-bars tort claims for personal injury filed after its limitations period.

Polidoro v. Saluti · filed 2017-01-10(a)

We add that any tort claims “for an injury to the person cause by the wrongful act[ or] neglect . . . of any person within [New Jersey]” would have been time-barred. See N.J. Stat. § 2A:14-2(a).
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Section 2A:14-2(a) bars personal injury complaints filed more than two years after the injury.

FREENY VS. JOHN DOES(SC-241-15, SC-242-15, SC-243-15, SC-244-15, SC-245-15,SC-246-15, SC-247-15, CUMBERLAND AND · filed 2017-06-06(a)

In addition, plaintiff's complaints that were filed based upon injuries to his person that occurred more than two years prior to a complaint's filing date were properly dismissed as being barred by the statute of limitations.
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Section 2A:14-2 sets a two-year limitations period for personal injury claims; courts use that period for § 1983 claims arising in New Jersey.

Parker v. County of Bergen · filed 2017-06-19

In New Jersey, the statute of limitations for personal injury claims is two years. See N.J. Stat. Ann. 2A:14-2. ... The District Court, therefore, correctly concluded that Parker’s claims were untimely.
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Section 2A:14-2's two-year limitations period governs invasion of privacy, AIDS Assistance Act, and medical malpractice claims arising from the unauthorized disclosure of a patient's HIV-positive status.

JOHN SMITH VS. ARVIND R. DATLA, M.D.(L-1527-15, MERCER COUNTY AND STATEWIDE) · filed 2017-07-12

Accordingly, we hold that an action for invasion of privacy by public disclosure of private facts that is premised on conduct such as the unauthorized disclosure of plaintiff's HIV-positive status present here constitutes a claim for "injury to the person" of the plaintiff and is governed by the two-year statute of limitations set forth in N.J.S.A. 2A:14-2. See ibid. We further hold that plaintiff's claims for medical malpractice and violation of the Act, which arise from the same operative facts, are likewise governed by the two-year statute of limitations set forth in N.J.S.A. 2A:14-2.
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Section 2A:14-2 sets a two-year limit for personal injury claims; a claim first brought against a defendant after that period is untimely if fictitious-party relation back is unavailable.

REZNIK VS. AMERICAN HONDA MOTOR CO., INC. (L-4023-12, PASSAIC COUNTY AND STATEWIDE) · filed 2017-07-13

The trial court erred in denying DCH's motion to dismiss the complaint on the ground plaintiff failed to satisfy the applicable two-year statute of limitations. See N.J.S.A. 2A:14- 2.
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Section 2A:14-2 sets a two-year deadline for personal injury claims; the court applied that deadline in denying a late request to add a defendant.

BRADLEY VS. DYNAMIC CAPITAL PROPERTY(L-0246-14, ESSEX COUNTY AND STATEWIDE) · filed 2017-10-20

This was also months before the statute of limitations expired on plaintiff's claim on January 16, 2016, yet plaintiff did not move to amend the complaint to identify the true owner until March 30, 2016, and then only after defendant had moved for summary judgment. ... See N.J.S.A. 2A:14-2.
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Section 2A:14-2 supplies the two-year limitations period for personal injury actions, which applies to § 1983 claims brought in New Jersey.

Woodyard v. County of Essex · filed 2013-03-05

In New Jersey, § 1983 claims are subject to New Jersey‟s two-year statute of limitations on personal...injury actions. See Dique, 603 F.3d at 185; see also N.J. Stat. Ann. § 2A:14-2. Accordingly, Woodyard‟s claims are subject to this two-year period.
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Section 2A:14-2 sets a two-year limitations period for personal injury claims, which the court applied to Bivens claims filed in New Jersey.

LEINHEISER v. HOEY · filed 2020-09-08

New Jersey’s statute of limitations for personal injury actions is two years. See N.J. Stat. § 2A:14–2.
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Section 2A:14-2(a) sets a two-year limitations period for personal injury actions, which governs Section 1983 claims arising in New Jersey.

AUSTINO v. CITY OF VINELAND · filed 2020-09-14(a)

Under New Jersey law, personal injury actions are subject to a two-year limitations period. See N.J.S.A. § 2A:14–2(a).
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Section 2A:14-2(a) sets a two-year limitations period for personal injury actions, which applies to § 1983 claims arising in New Jersey.

HALLOCK v. MERCK & CO., INC. · filed 2020-09-14(a)

Under New Jersey law, personal injury actions are subject to a two-year limitations period. See N.J.S.A. § 2A:14–2(a).
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Section 2A:14-2 provides a two-year limitations period for New Jersey personal injury actions, which applies to § 1983 claims arising there.

SOSA v. COUNTY OF HUDSON, NEW JERSEY · filed 2020-09-28

Since the cause of action arose in New Jersey, the limitations period is two years.
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Section 2A:14-2 sets a two-year limitations period for personal injury claims in New Jersey, including § 1983 claims that accrue there.

LOVE v. JOHN DOES 1-9 · filed 2020-09-28

A two-year statute of limitations period applies to personal injury claims in New Jersey. N.J.S.A. 2A:14-2. Thus, claims brought pursuant to § 1983 that accrued in New Jersey are subject to a two-year statute of limitations period.
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Section 2A:14-2 gives NJLAD claims a two-year limitations period, not seven years.

JONES v. FOX ROTHSCHILD LLP · filed 2020-10-21

There is no merit to Plaintiff’s argument that the statute of limitations under N.J.S.A. 2A:14-2 has been expanded from two to seven years for NJLAD claims.
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Section 2A:14-2 sets a two-year limitations period for personal injury claims in New Jersey, which applies to Section 1983 claims arising there.

CURTIS v. NEW JERSEY STATE POLICE · filed 2020-12-30

Therefore, any claims accruing prior to December 6, 2017 would generally be time-barred. See N.J. Stat. Ann. § 2A:14-2. ... Afier review, the Court finds that the statute of limitations bar is not apparent on the face of Curtis’s Complaint.
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Section 2A:14-2 provides a two-year limitations period for personal-injury claims, which applies to § 1983 claims brought in New Jersey.

MCKINNEY v. LANIGAN · filed 2021-01-28

Under New Jersey law, there is a two-year statute of limitations period for personal- injury torts. N.J. Stat. Ann. § 2A:14–2. Because a § 1983 claim is characterized as a personal- injury claim, such claims are governed by the applicable state’s statute of limitations for personal-injury claims.
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Section 2A:14-2 provides a two-year limitations period for personal injury actions, which the court applied to the Bivens claims.

ALEXIS v. SESSIONS · filed 2021-02-08

New Jersey’s statute of limitations for personal injury actions is two years. See N.J. Stat. § 2A:14–2.
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Section 2A:14-2 supplies New Jersey’s two-year limitations period for personal injury claims, which applies to federal civil rights claims arising in the state.

Edwards v. The Hillman Group Company for · filed 2021-03-01

Because Edwards’ federal civil rights claims against all defendants stem from conduct that ended at the latest when his 2013 civil rights case concluded in April 2018, more than two years ago, they would now be time-barred. See Dique v. N.J. State Police, 603 F.3d 181, 185 (3d Cir. 2010) (explaining that “[a] section 1983 claim is characterized as a personal-injury claim and thus is governed by the applicable state’s statute of limitations for personal-injury claims,” which in New Jersey is two years); ... see also N.J. Stat. Ann. § 2A:14–2.
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Section 2A:14-2 provides a two-year limitations period for personal-injury claims, including § 1983 claims brought in New Jersey.

BELL v. United States · filed 2021-03-26

Under New Jersey law, there is a two-year statute of limitations period for personal-injury torts. N.J. Stat. Ann. § 2A:14–2. Therefore, Plaintiff’s § 1983 claims are governed by a two-year statute of limitations.
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Section 2A:14-2 provides a two-year limitations period for personal-injury claims, including § 1983 claims brought in New Jersey.

MCKINNEY v. FITZGERALD · filed 2022-01-10

Under New Jersey law, there is a two-year statute of limitations period for personal- injury torts. N.J. Stat. Ann. § 2A:14–2.
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Section 2A:14-2 requires personal injury actions to be filed within two years of accrual.

RAMSAROOP v. UNITED AIRLINES, INC. · filed 2022-02-15(a)

This action is barred by the New Jersey statute of limitations. New Jersey requires personal injury actions to be filed within two years of their accrual.
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Section 2A:14-2 sets a two-year limitations period for personal injury claims, including intentional infliction of emotional distress.

SWARTZ v. THE BOARD OF TRUSTEES AT THE UNIVERSITY OF PENNSYLVANIA · filed 2022-03-23

Under either state’s laws, Swartz’s claims are time-barred. Pennsylvania and New Jersey have a two-year statute of limitations for personal injury claims, including intentional infliction of emotional distress. 42 Pa. Cons. Stat. Ann. § 5524(7); N.J. Stat. Ann. § 2A:14–2.
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Section 2A:14-2 sets a two-year limitations period for personal injury claims, including claims arising from injuries sustained by minors.

MCCRACKEN v. COUNTY OF UNION NEW JERSEY · filed 2022-07-15

In New Jersey, personal injury claims, including those brought on behalf of those who were minors at the time of the events in question, are subject to a two year statute of limitations.
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Section 2A:14-2(a) requires personal-injury actions, including negligence and emotional-distress claims, to be filed within two years.

CAPRIO v. NUTLEY PARK SHOPRITE (L-3791-21, ESSEX COUNTY AND STATEWIDE) · filed 2022-09-21(a)

There is no dispute regarding the applicable statute of limitations for each cause of action in plaintiff's complaint: one year for his defamation claim, see N.J.S.A. 2A:14-3; two years for his negligent or intentional infliction of emotional distress claim, see N.J.S.A. 2A:14-2; Fraser v. Bovino, 317 N.J. Super. 23, 34 (App. Div. 1998) ("The claims asserted for negligence and infliction of emotional distress are governed by the two-year statute of limitations contained in N.J.S.A. 2A:14-2."); and two years for his CRA claims, see Lapolla v. Cnty. of Union, 449 N.J. Super. 288, 298 (App. Div. 2017) (holding the statute of limitations for claims under the CRA is two years as set forth in N.J.S.A. 2A:14-2(a)).
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Section 2A:14-2 provides the two-year personal injury limitations period applied to § 1983 claims in New Jersey; a claim is not dismissed as untimely when the complaint may allege an injury within that period.

COLON v. CUMBERLAND COUNTY D.O.C. · filed 2023-12-01

The Third Circuit has held that “New Jersey’s two-year limitations period on personal injury actions, N.J.S.A. 2A:14–2, applies to a civil rights claim under § 1983.” ... Here, it is not clear on the face of the pleading that Plaintiff’s claims against Smith are barred, as Plaintiff’s Complaint includes allegations that may fall within the applicable two-year limitations period.
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Section 2A:14-2 gives a plaintiff two years to file a personal injury claim, and that period applies to § 1983 claims arising in New Jersey.

HASSANI v. STATE OF NEW JERSEY · filed 2024-11-22

“New Jersey law gives litigants two years to file a personal-injury claim.” Id. (citing N.J. Stat. Ann. § 2A:14-2); see also Wallace v. Kato, 549 U.S. 384, 387 (2007). ... Here, after giving Plaintiff the benefit of the “prison mailbox rule,” see Houston v. Lack, 487 U.S. 266, 270–71 (1988), his Title VI claims and many of his § 1983 claims are barred by the two-year statute of limitations because they accrued more than two years prior to his filing of the instant Complaint on July 12, 2021.
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Section 2A:14-2 provides a two-year limitations period for personal-injury claims, including § 1983 claims arising in New Jersey.

KHAWAM v. NEW JERSEY LAWYERS FUND FOR CLIENT PROTECTION · filed 2025-02-27

New Jersey “mandates a two-year statute of limitations period for personal-injury torts.” Id. (citing N.J. Stat. Ann. § 2A:14-2). Thus, a § 1983 claim arising in New Jersey has a two-year statute of limitations.
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Section 2A:14-2 requires an action for injury to the person caused by a wrongful act, neglect, or default to be commenced within two years of accrual.

SON V. LYNCH · filed 2025-03-17

Similarly, N.J.S.A. 2A:14–2 provides that an action for an injury to the person caused by a wrongful act, neglect, or default must be commenced within two years of accrual of the action. ... Therefore, to the extent Plaintiff asserts claims arising from incidents that occurred between 2002 and 2019, his claims are time-barred under 42 U.S.C. § 1983, 28 U.S.C. § 2401(b), and N.J.S.A. 2A:14–2.
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Section 2A:14-2 provides a two-year limitations period for personal injury actions, which the court applied to the civil rights claim.

JIMOH v. RAIMONDO · filed 2025-03-24

“In New Jersey that statute is N.J.S.A. 2A:14—2, which provides that an action for an injury to the person caused by a wrongful act, neglect, or default, must be convened within two years of accrual of the cause of action.” ... Finally, as all of Plaintiff’s factual allegations relate to events and injuries that occurred nearly five years ago, in 2020, the Court finds that Plaintiff's first cause of action is time-barred.
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Section 2A:14-2 applies a two-year limitations period to negligence, negligent infliction of emotional distress, intentional infliction of emotional distress, and negligent supervision claims.

GALLOWAY v. CITY OF WEST ORANGE · filed 2025-03-28

Plaintiff’s other allegedly untimely tort claims—negligence, negligent infliction of emotional distress, intentional infliction of emotional distress, and negligent supervision—are subject to a two-year statute of limitations. N.J. Stat. Ann. § 2A:14-2.
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Section 2A:14-2(a) requires personal injury actions to be brought within two years after the cause of action accrues.

Rennie v. the Valley Hospital · filed 2025-04-17(a)

We agree with the trial court's decision to dismiss Martkovsky from the litigation because his joinder is prohibited by the pertinent statute of limitations and because the trial court found that plaintiff was aware of Martkovsky's factual involvement in the matter from the inception of it. ... Actions to recover damages for personal injury in New Jersey must be brought within two years after the cause of action accrues.
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Section 2A:14-2 provides a two-year limitations period for personal injury actions, which applies to claims under 42 U.S.C. §§ 1983 and 1985 in New Jersey.

Sexton v. New Jersey Department of Corrections · filed 2025-05-23

The statutes of limitations for actions under 42 U.S.C. §§ 1983 and 1985 are taken from New Jersey’s personal injury statute, N.J.S.A. § 2A:14-2, which is two years.
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Section 2A:14-2(a) provides a two-year limitations period for personal-injury claims, including claims under the New Jersey Civil Rights Act.

DOE v. HILLSBOROUGH TOWNSHIP BOARD OF EDUCATION · filed 2025-05-29(a)

“New Jersey’s two-year statute of limitations for personal-injury claims also applies to claims under the NJCRA.” ... Accordingly, it is apparent on the face of the Amended Complaint that Counts One, Three, Five, Six, and Eight are time-barred, and the Court dismisses these claims without prejudice.
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Section 2A:14-2(a) requires personal injury actions to be brought within two years after the injury.

Jimenez-Peguero v. Royal Packaging, LLC · filed 2025-06-04(a)

Actions to recover damages for personal injury must be brought within two years after the date of injury. N.J.S.A. 2A:14-2(a).
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Section 2A:14-2 sets a two-year limitations period for personal injury actions, which the court applied to a Bivens claim brought in New Jersey.

ALLEN · filed 2025-10-27

New Jersey’s statute of limitations for personal injury actions is two years. See N.J. Stat. § 2A:14–2.
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Section 2A:14-2 gives a personal injury plaintiff two years from accrual to file suit; the court applied that period to a federal direct action against the alleged tortfeasor’s insurer.

JEONG · filed 2025-12-30

The two-year statute of limitations ran in 2022, before plaintiff filed this action. N.J.S.A. § 2A:14-2 (two years from date of accrual); Ben Elazar v. Macrietta Cleaners, Inc., 230 N.J. 123, 134-35 (2017) (accrual date is date of injury, unless discovery rule applies).
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Section 2A:14-2(a) requires personal injury actions to be commenced within two years after the cause of action accrues.

Edward McNeill, Jr. v. Port Authority of Ny & Nj · filed 2026-01-02(a)

Actions for personal injuries must be commenced within two years after the cause of action accrues. Baird v. Am. Med. Optics, 155 N.J. 54, 65 (1998) (citing N.J.S.A. 2A:14-2(a)). There is no dispute plaintiff's cause of action accrued on June 8, 2022, and that he failed to assert a claim against EWR ConRAC and SIXT before the two-year SOL expired.
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Section 2A:14-2(a) gives plaintiffs two years after accrual to bring the civil rights and tort claims at issue here.

C.A.L. v. State of New Jersey · filed 2026-01-28(a)

The parties agree that all claims in the complaint are governed by the two-year statute of limitations set forth in N.J.S.A. 2A:14-2(a) (“Except as otherwise provided by law, every action at law for an injury to the person caused by the wrongful act, neglect or default of any person within this State shall be commenced within two years next after the cause of any such action shall have accrued . . . .”). The question for us is when each of plaintiffs’ causes of action accrued.
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Section 2A:14-2(a) sets a two-year limitations period for personal injury claims, including Section 1983 claims arising in New Jersey.

PEREZ · filed 2026-01-30(a)

New Jersey, where Plaintiff’s claims arise, has a two-year statute of limitations for claims of “injury to the person.”
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Section 2A:14-2(a) requires actions for personal injury damages to be brought within two years after the cause of action accrues.

Johnson v. Lazo · filed 2026-02-17(a)

Under N.J.S.A. 2A:14-2(a), actions to recover damages for personal injury must be brought within two years after the cause of action accrues.
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Personal injury claims are subject to a two-year statute of limitations.

Myers v. Benucci · filed 2026-03-03

Personal injury claims, however, have a two-year statute of limitations.
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Section 2A:14-2(a) requires a personal injury claim to be filed within two years of accrual, even when it is pleaded as a breach of express warranty.

Cappello v. Cicchetti, LLC · filed 2026-03-17(a)

Applying the long-standing precedent established in Heavner, we conclude the governing statute of limitations period was two-years as provided under N.J.S.A. 2A:14-2(a). The Legislature's subsequent adoption of the PLA, which excepts express warranty claims, does not alter a plaintiff's obligation to file a complaint within two years of when their personal injury cause of action accrued.
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Section 2A:14-2(a) gives plaintiffs two years to file LAD claims; the continuing-violation doctrine can delay when that period begins.

Acey v. City of Paterson · filed 2026-04-02(a)

We discern no error with the judge's rejection of the continuing violation doctrine and grant of summary judgment to defendants, dismissing counts one and three of plaintiff's complaint as time-barred under LAD's two-year statute of limitations. "The statute of limitations for LAD claims is two years." Roa v. Roa, 200 N.J. 555, 556 (2010); N.J.S.A. 2A:14–2(a).
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Section 2A:14-2 provides a two-year limitations period for civil conspiracy and intentional infliction of emotional distress claims.

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

Likewise, Appellants filed the underlying complaint more than two years after they became aware of the bases for their civil conspiracy and intentional infliction of emotional distress claims (Counts Six and Seven). See N.J. Stat. Ann. § 2A:14-2. Accordingly, those claims were properly dismissed as time barred.
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Section 2A:14-2 provides a two-year limitations period for intentional infliction of emotional distress claims, subject to accrual and tolling.

WILLIAMS v. VERIZON · filed 2020-03-12

See also N.J. Stat. Ann. § 2A:14-2 (general two-year statute of limitations, subject to doctrines of accrual and tolling). ... Moreover, while it is not expressly stated, it appears that these decorations were put up during the 2014 holiday season, well outside the two-year statute of limitations.
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Section 2A:14-2 sets a two-year limitations period for personal injury claims, which also governs New Jersey claims under 42 U.S.C. §§ 1983 and 1985.

Lloyd v. Ocean Township Counsel · filed 2021-04-26

“In New Jersey, where [Lloyd’s] claim arose, personal injury claims are governed by a two-year statute of limitations.” Est. of Lagano v. Bergen Cty. Prosecutor’s Off., 769 F.3d 850, 859 (3d Cir. 2014) (citing N.J. Stat. Ann. § 2A:14–2). ... Accordingly, because the claims were filed in October 2018, well after March 6, 2016, they were time-barred.
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Section 2A:14-2 provides a two-year limitations period for claims under § 1983 and the New Jersey Civil Rights Act.

Edward Scanlon, IV v. Lawson · filed 2022-06-06

The parties agree that New Jersey law applies here and provides a two-year statute of limitations for both Scanlon’s claims under 42 U.S.C. § 1983 and the New Jersey Civil Rights Act. See N.J.S.A. § 2A:14-2; Dique v. N.J. State Police, 603 F.3d 181, 185 (3d Cir. 2010). Because Scanlon was a minor when the relevant conduct occurred, his claims were tolled until he turned eighteen on April 1, 2014. See N.J. Stat. Ann. § 2A:14-21. Scanlon’s claims were therefore required to be asserted by April 1, 2016.
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Section 2A:14-2 provides a two-year limitations period for actions for injury to a person.

Ouaziz v. City of Jersey · filed 2023-10-24

The District Court correctly observed the longest applicable statute of limitations period to his claims was two years and Ouaziz did not allege a basis for equitable tolling or a later accrual date, so his claims based on incidents in 2019 and prior are time-barred. See, e.g., 42 U.S.C. § 1986 (one year); Dique v. N.J. State Police, 603 F.3d 181, 185 (3d Cir. 2010) (two years for claim under 42 U.S.C. §§ 1983 and 1985 arising in New Jersey); N.J.S.A. 2A:14-2.
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Injury to the person

Section 2A:14-2’s two-year limit for injury to the person does not cover a claim for commercial appropriation of a person’s name and likeness.

Canessa v. Kislak, Inc. · filed 1967-10-19

So here, since this action for "invasion of privacy" involves no "force to the person," it would not have been enforceable by trespass vi et armis and is not comprehended within the phrase "injury to persons" contained in N.J.S. 2A:14-2.
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Section 2A:14-2’s two-year limitations period applies only when the gravamen of the claim is injury to the person, so it does not cover a legal malpractice claim for pecuniary loss.

Carney v. Finn · filed 1976-12-06

We are satisfied the two-year statute applies only where the gravamen of the plaintiff's complaint is injury to the person. 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.
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Section 2A:14-2’s two-year personal injury limitations period does not govern a § 1981 employment discrimination claim founded on contractual rights, even when the plaintiff also seeks damages for resulting physical injuries.

Page v. Curtiss-Wright Corporation · filed 1971-10-18

This is said by defendant to be the New Jersey two-year statute of limitations (N.J.S.A. 2A:14-2), citing Hughes v. Smith, 264 F.Supp. 767 (D.N.J.1967), aff’d. per curiam, 389 F.2d 42 (3 Cir. 1968), which applied the two-year New Jersey personal injury statute of limitations (N.J.S.A. 2A:14-2) to bar a civil rights claim under 42 U.S.C. § 1983. Although it is New Jersey’s statute of limitations which applies, Hughes is inapposite. ... Accordingly, it is New Jersey’s six-year statute of limitations (N.J.S.A. 2A:-14-1) which, as a matter of federal law, is determined to govern plaintiff’s claim.
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Section 2A:14-2’s two-year limitations period governs parents’ individual claims for medical expenses, pain and suffering, embarrassment, and humiliation.

Henry v. Richardson-Merrell, Inc. · filed 1973-11-14

In New Jersey the two-year limitations period of N.J.S.A. 2A :14-2 governs the timeliness of a parent’s individua] claims for medical expenses, pain and suffering, embarrassment, humiliation, etc.
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Section 2A:14-2’s two-year limit applies when the defendant caused an injury to the person, but not to a legal malpractice claim for the loss of recovery in a personal injury action.

Fuschetti v. Bierman · filed 1974-04-30

By its language the two-year statute applies only where defendant is charged with having "caused" plaintiff an injury to the person. 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.
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Section 2A:14-2’s two-year tort limitations period does not govern a demand for arbitration under an uninsured motorist endorsement.

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

Defendant Dierolf's demand for arbitration under Selected Risks' uninsured motorist endorsement is not governed by the statute of limitations applicable to torts and he may not be denied access to arbitration of his claim on the basis of that statute.
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Section 2A:14-2’s two-year limit applies to physical or mental injuries, based on the nature of the injury; a claim for lost wages from discharge falls outside it.

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

N.J.S.A. 2A:14-2 is also inapplicable, since it relates to suits "at law for an injury to the person. " This statute applies to suits involving a wide variety of physical and mental injuries, regardless of whether they arose out of a contractual obligation or from some tortious conduct. Heavner v. Uniroyal, Inc., 118 N.J. Super. 116 (App. Div. 1972). This is so because it is the nature of the injuries, not the theory of recovery, which is controlling. Atlantic City Hospital v. Finkle, 110 N.J. Super. 435 (Law Div. 1970). In contrast, plaintiff in the present suit is not seeking damages for "an injury to her person." Rather, what she seeks are damages to compensate her for her wage loss.
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Section 2A:14-2 does not apply to an insured’s claim against a carrier for benefits provided by an insurance policy.

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

We do not, however, regard an action by an insured against his carrier for benefits provided by the policy to be based on an injury to the person within the intendment of N.J.S.A. 2A:14-2. It is, to the contrary, an action for recovery on a contractual claim within the intendment of N.J.S.A. 2A:14-1.
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Law changed since Montells v. Haynes (N.J. July 27, 1993) later set a two-year period for LAD claims whose operative facts arise after that date; it left earlier claims under the prior law.

Section 2A:14-2’s two-year limit does not apply to an employment discrimination claim alleging injury to property rights.

Leese v. Doe · filed 1981-12-02

The question presented by this case is whether a claim under the Civil Rights Act, N.J.S.A. 10:5-1 et seq., is subject to a two-year statute of limitation ( N.J.S.A. 2A:14-2) or a six-year statute ( N.J.S.A. 2A:14-1). ... The present case, though brought under our Civil Rights Act, also involves employment discrimination and the injury to plaintiff's property rights which allegedly resulted. As such, the six-year limitation of N.J.S.A. 2A:14-1 governs the timeliness of plaintiff's action.
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Law changed since Same change as noted above.

Section 2A:14-2’s two-year period for personal injury does not govern an employment discrimination action seeking relief for a broad range of alleged conduct rather than bodily injury.

Skadegaard v. Farrell · filed 1984-01-19

I also agree with the court’s determination in Leese, that as between the two year period for personal injury, N.J.S.A. 2A:14-2, and the six year period for contractual or other tortious injury, N.J.S.A. 2A:14-1, the latter applies to a case such as the one before me.
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Section 2A:14-2 bars an emotional distress claim filed after the limitations period has expired.

Goncalvez v. Patuto · filed 1983-03-11

We do, however, agree with defendant that the father's cause of action for emotional distress resulting from the witnessing of his son's death is precluded by the statute of limitations. N.J.S.A. 2A:14-2. He sustained that injury in 1976. The right of action was thus barred long before the 1980 commencement of this suit.
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Section 2A:14-2 bars a parent's independent wrongful birth claim filed after its two-year limitations period, even when the child's claim is timely.

Procanik by Procanik v. Cillo · filed 1984-08-01

The defect in the parents' argument in the present case is that their right to recover is not "because of injury" to their child, but because of direct injury to their own independent rights. Consequently, the parents' right to recover is not derivative from the claim of the child and is, therefore, barred by N.J.S.A. 2A:14-2.
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Law changed since Same change as noted above.

Section 2A:14-2 does not govern an age discrimination action under the New Jersey Law Against Discrimination; the six-year period in § 2A:14-1 applies.

Nolan v. Otis Elevator Co. · filed 1984-11-29

Defendant contends here that the action is barred by the time limitations expressed in the New Jersey Law Against Discrimination and the Statute of Limitations, N.J.S.A. 2A:14-2. In our view the requirement that the complaint be filed within 180 days after the alleged act of discrimination, N.J.S.A. 10:5-18, has reference only to administrative proceedings initiated within the Division of Civil Rights. Moreover, we conclude that the applicable time limitation is that stated in N.J.S.A. 2A:14-1, "6 years next after the cause of action shall have accrued." On this view the action is timely brought.
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Section 2A:14-2’s two-year limit for personal injury claims does not displace the Port Authority’s specific one-year limit.

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

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.
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Law changed since Same change as noted above.

Section 2A:14-2’s two-year limitations period does not govern claims under the New Jersey Law Against Discrimination; those claims have a six-year period.

Carrington v. RCA Global Communications, Inc. · filed 1991-04-26

Therefore, consistent with the uniform view of the New Jersey state courts, I conclude that the six-year statute of limitations for “tortious injury to the rights of another” applies to plaintiff’s claims under the NJLAD.
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Law changed since Same change as noted above.

Section 2A:14-2's two-year period covers direct physical injuries and does not govern NJLAD employment discrimination claims.

Lautenslager v. Supermarkets Gen. Corp. · filed 1991-06-28

N.J.S.A. 2A:14-2 was intended by the legislature to cover claims of actual, physical injury such as negligence, assault and battery, and actions for trespass vi et armis. ... Under the circumstances, this Court is of the opinion that NJLAD claims are characteristic of common law actions on the case. They are therefore governed by the six year statute of limitations: N.J.S.A. 2A:14-1.
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Section 2A:14-2 provides a two-year limitations period that does not generally govern IDEA fee applications.

B.K. v. Toms River Board of Education · filed 1998-03-30

... we reject plaintiffs argument that the two year statute of limitations found in N.J.Stat.Ann. § 2A:14-2 is the applicable limitations period in IDEA fee applications in general.
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Section 2A:14-2's two-year limitations period applies to legal malpractice claims arising from criminal defense when the alleged harm is personal injury, even if the prosecution also caused economic loss.

McGrogan v. Till · filed 2000-02-01

We also conclude, as an alternative ground for our affirmance of the judgment, that the two-year limitations period applies. ... We are persuaded that the consequences of Till's alleged malpractice qualify as personal injuries.
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Section 2A:14-2 imposes a two-year limit on a parishioner's claim that a clergy member breached a fiduciary duty arising from a counseling relationship.

Balliet v. Fennell · filed 2004-03-30

Applying these principles, we hold that a cause of action for breach of the fiduciary obligation by a member of the clergy who has established a counseling relationship with a parishioner is governed by the two-year "injury to the person" statute of limitations.
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The two-year limitations period applies to personal injury claims based on sexual assault, even when the assault was intentional.

Zuidema v. Pedicano · filed 2004-11-24

Personal injury claims based on sexual assault, even as an intentional act, are subject to the two-year statute of limitations.
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Section 2A:14-2’s two-year period does not govern a false-light privacy claim grounded in defamatory publication.

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

Based on our analysis of the record and the applicable law, we, too, are persuaded that the nature of plaintiff's invasion of privacy claim is essentially one of defamation, and that the type of alleged objectionable conduct by defendant is dissimilar to that giving rise to the two-year statute of limitations ("intrusion on seclusion"), Rumbauskas, supra, or six-year limitations period ("appropriation"), Canessa, supra .
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Civil rights actions

Section 2A:14-2 provides a two-year limitations period for personal-injury claims, which governs § 1983 claims arising in New Jersey.

Camarao v. State of New Jersey · filed 2025-07-09

New Jersey “mandates a two-year statute of limitations period for personal-injury torts.” Id. (citing N.J. Stat. Ann. § 2A:14- 2). Because the most recent allegation in the Complaint related to the New Jersey Defendants is February 2021, the Court finds that Plaintiff’s claims against the New Jersey Defendants are time- barred.
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Section 2A:14-2’s general two-year limitations period applies to § 1983 claims arising in New Jersey, including claims involving sexual assault.

BUNDY v. CUMBERLAND COUNTY · filed 2022-10-11

Consequently, New Jersey’s general two-year limitations period still applies to the § 1983 claims in this case.
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Section 2A:14-2’s two-year limitations period applies to a civil rights damages action alleging personal injuries inflicted by police officers.

Hughes v. Howard Smith and Robert Tatum · filed 1968-02-01

We are satisfied that the New Jersey statute of limitations controlling this action is N.J.S.A. 2A:14-2 above quoted.
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Section 2A:14-2 provides a two-year limitations period applicable to a federal civil rights action filed in New Jersey.

Thomas v. Harry R. Howard, Esquire · filed 1972-02-09

The New Jersey statute of limitations applicable to this case would be N.J.S.A. 2A:14-2, which prescribes a period of two years. Since appellant did not file this action until March 25, 1970, his cause of action has been outlawed by the statute of limitations.
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Section 2A:14-2’s general limitations period does not govern a civil rights damages action against a municipality when the more specific limit in N.J.S.A. 59:8-8 applies.

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.
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Section 2A:14-2 sets a two-year limit for personal injury actions, but that limit did not apply retroactively to this pre-Wilson § 1983 suit for recovery of seized property.

Brown v. Foley · filed 1987-01-26

In New Jersey that statute is N.J.S.A. 2A:14-2, which provides that an action for injury to the person caused by wrongful act, neglect or default must be commenced within two years of the accrual of the cause of action. ... We conclude that it should have been applied in the present case and that the application to this case of the two-year statute of limitations applicable to state actions for personal injuries was erroneous.
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New Jersey’s two-year limitations period for personal injury actions applies to claims under 42 U.S.C. § 1983.

Genty v. Resolution Trust Corporation · filed 1991-07-08

This court subsequently held that New Jersey's two-year limitations period on personal injury actions, N.J.S.A. 2A:14-2, applies to a civil rights claim under section 1983. Cito v. Bridgewater Tp. Police Dept., 892 F.2d 23, 25 (3rd Cir.1989). Thus, the district court here correctly applied a two-year limitations period to the Gentys' section 1983 claim.
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Section 2A:14-2 supplies the two-year limitations period for section 1983 actions in New Jersey.

Wilson v. City of Atlantic City · filed 1992-06-22

Under New Jersey law, the relevant period for section 1983 purposes is two years.
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Section 2A:14-2 provides a two-year limitations period for these injury claims, tolled while the claims are pending in federal court.

Fagan v. City of Vineland · filed 1992-07-30

In this case, the applicable statute of limitations is two years. N.J.S.A. 2A:14-2. However, New Jersey courts have tolled the statute of limitations during the pendency of a claim in federal court.
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Section 2A:14-2 supplies the two-year limitations period for personal injury actions, which applies to § 1983 claims in New Jersey.

Montgomery v. De Simone · filed 1998-10-16

We have since held that New Jersey's two-year limitations period on personal injury actions, N.J.S.A. 2A:14-2, applies to a civil rights claim under § 1983. ... The parties are therefore correct in assuming that a two-year limitations period applies to Montgomery’s § 1983 claims.
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Section 2A:14-2 provides a two-year limitations period for personal injury actions, which applies to Section 1981 claims in New Jersey.

Lewis v. United Air Lines, Inc. · filed 2000-09-28

Thus, New Jersey’s two-year statute of limitations applicable to personal injury claims governs the timeliness of Plaintiffs Section 1981 claim.
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Section 2A:14-2 supplies a two-year limitations period for § 1983 and § 1985(3) claims brought in New Jersey.

Cox v. Fort Lee · filed 2005-11-04

“In New Jersey that statute is N.J.S.A. 2A: 14-2, which provides that an action for an injury to a person caused by a wrongful act, neglect, or default, must be convened within two years of accrual of the cause of action.” ... This is so because, regardless of whether Cox’s claims accrued on April 10, 1998, or on June 29, 2000, his complaint – submitted on December 16, 2002 – is barred by the applicable statute of limitations in that it was received and filed more than two years after the latter date.
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Section 2A:14-2 supplies a two-year limitations period for § 1983 personal injury claims arising in New Jersey.

O'Connor v. Newark · filed 2006-03-13

For section 1983 actions in New Jersey, “that statute is N.J.S.A. 2A:14-2, which provides that an action for injury to the person caused by wrongful act, neglect, or default, must be convened within two years of accrual of the cause of action.” Brown v. Foley, 810 F.2d 55, 56 (3d Cir. 1987). The limitations period for O’Connor’s claims is therefore two years.
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Section 2A:14-2 provides the two-year limitations period that applies to § 1983 civil rights claims in New Jersey.

Wakefield v. Moore · filed 2006-12-07

We have held that ... New Jersey’s two-year limitations period for personal injury actions, N.J.S.A. 2A:14-2, applies to civil rights claims under § 1983.
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Section 2A:14-2 supplies the two-year limitations period for § 1983 claims filed in New Jersey.

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

In this case, the applicable statute of limitations is New Jersey’s two-year statute of limitations for personal injury actions under N.J.S.A. 2A:14-2.
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Section 2A:14-2 sets a two-year limitations period for personal injury claims, which applies to § 1983 claims that accrue in New Jersey.

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

In New Jersey, N.J.S.A. 2A:14-2 imposes a two-year limitations period for personal injury claims; therefore, claims brought under 42 U.S.C. § 1983 that accrued within New Jersey are subject to a two-year statute of limitations.
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Section 2A:14-2 provides a two-year limitations period for personal injury actions, which applies to Bivens claims brought in New Jersey.

Hughes v. Knieblher · filed 2009-07-27

New Jersey’s statute of limitations for personal injury causes of action is two years. N.J. Stat. Ann. § 2A:14-2. ... Here, as the District Court concluded, Hughes missed the statute of limitations for his exhausted claims. He filed his complaint on July 6, 2007. Claims relating to the floor-stripping incidents (April 2004) and the job transfer (May 2004) fell outside of the two-year limitations period.
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Section 2A:14-2’s two-year limitations period applies to civil rights claims under § 1983 in New Jersey.

Baker v. Wittevrongel · filed 2010-01-29

We have held that New Jersey’s two-year limitations period on personal injury actions, N.J.S.A. 2A:14-2, applies to civil rights claims under § 1983. ... His complaint was filed in January 2008, well after the limitations period had expired.
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Section 2A:14-2 provides a two-year limitations period for personal injury claims, which applies to § 1983 claims brought in New Jersey.

Rondon v. Passaic Cty Jail · filed 2010-03-11

Therefore, Rondon had two years from the time his cause of action accrued in which to file his complaint.
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Section 2A:14-2(a) gives plaintiffs two years to bring a New Jersey Civil Rights Act claim; a claim for denial of a required vote accrues when the vote should have taken place.

Save Camden Pub. Sch. v. Camden City Bd. of Educ. · filed 2018-04-24(a)

The statute of limitations for claims under the CRA is two years. ... We hold that the cause of action accrued on April 23, 2014, when the school district classification vote should have been held. ... Instead, the cause of action accrued on the date that the vote did not take place.
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Section 2A:14-2(a) gives an NJCRA unreasonable-search-and-seizure claim a two-year filing period that begins when the search and seizure occurs.

CAMPBELL VS. KELLEY LAVERY (L-3366-18, PASSAIC COUNTY AND STATEWIDE) · filed 2021-05-25(a)

Having reviewed the record, we affirm for the reasons stated by Judge Frank Covello in ... his well-reasoned written decisions issued with the January 31, 2020 order and the September 17, 2019 order. ... Judge Covello found that violations of an individual's Fourth Amendment right occur where there is an unreasonable search and seizure and claims under the NJCRA are subject to a two-year statute of limitation. Lapolla v. Cnty. of Union, 449 N.J. Super. 288, 298 (App. Div. 2017); N.J.S.A. 2A:14-2(a). ... It follows that a claim for an unreasonable search and seizure brought under the NJCRA accrues at the time the action occurred .
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Section 2A:14-2(a) provides a two-year limitations period for NJCRA claims; one based on malicious prosecution accrues when the malicious-prosecution claim accrues.

Mosley v. State of New Jersey · filed 2025-07-02(a)

Because that aspect ... of plaintiff's NJCRA claim had the same accrual date as his VOP malicious - prosecution claims, it was not barred by the applicable two-year statute of limitations and the judges erred in dismissing it on that basis.
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Section 2A:14-2 supplies a two-year limitations period for § 1981 claims.

Cardenas v. Jon Massey James Rebo Robert Lipscher James Ciancia Deborah Poritz State of New Jersey · filed 2001-10-16

Cardenas’ § 1981 claims are subject to a two-year statute of limitations. See Goodman v. Lukens Steel Co., 482 U.S. 656, 662, 107 S.Ct. 2617, 96 L.Ed.2d 572 (1987); N.J. Stat. Ann. § 2A:14-2.
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Discovery rule

Section 2A:14-2 provides a two-year limitations period for § 1983 personal-injury claims in New Jersey; the discovery rule may delay when that period begins.

GREEN v. WARREN · filed 2025-06-20

“A claim raised under § 1983 is characterized as a personal-injury claim and thus is governed by the applicable state’s statute of limitations for personal-injury claims,” which, in New Jersey, is two years. McCargo v. Camden Cnty. Jail, 693 F. App’x 164, 166 (3d Cir. 2017) (first citing N.J. Stat. Ann. § 2A:14-2, then citing Dique v. N.J. State Police, 603 F.3d 181, 185 (3d Cir. 2010)). ... So, although the Court finds that Plaintiff’s claim against Dr. Neal is saved by the discovery rule, his claim against CCJ is not.
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Section 2A:14-2 provides a two-year limitations period for personal injury actions, including Section 1983 claims arising in New Jersey.

Lancaster v. New Jersey Transit Corporation · filed 2025-06-23

"In New Jersey, that statute is N.J.S.A. 2A:14-2, which requires that a suit for personal injury be commenced within two years from the accrual of the cause of action."
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Section 2A:14-2 sets a two-year limitations period for personal injury claims in New Jersey, which the court applied to the § 1983 retaliation claims.

SMITH v. D'ILIO · filed 2025-06-23

The statute of limitations for personal injury claims in New Jersey is two years. See N.J. Stat. § 2A:14-2.
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Section 2A:14-2 gives litigants two years to file a personal-injury claim, a period the court applied to the § 1983 claims.

MEYER v. STATE OF NEW JERSEY · filed 2025-06-30

... and New Jersey law gives litigants two years to file a personal-injury claim. See id. (citing N.J. Stat. Ann. § 2A:14-2).
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Section 2A:14-2 supplies a two-year limitations period for NJLAD and related tort claims.

DICKERSON v. NEW JERSEY INSTITUTE OF TECHNOLOGY · filed 2025-07-29

Likewise, claims brought under the NJLAD and any related tort claims are governed by a two-year statute of limitations under New Jersey law, which would have expired well before Dickerson II was filed.
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Section 2A:14-2 sets a two-year limit for claims arising from injury caused by another's wrongful act; the discovery rule may toll that period until the injured person has facts suggesting another may be responsible.

Weiss v. Borough of Franklin Lakes · filed 2025-07-31

The statute of limitations for a claim arising from an injury caused by the wrongful act of another is two years. N.J.S.A. 2A:14-2. ... The motion court correctly found there was no basis for ... application of the discovery rule and plaintiff's claims against Altona were untimely filed.
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Section 2A:14-2 supplies a two-year limitations period for New Jersey personal-injury claims, which applies to Section 1983 claims arising in New Jersey.

EXANTUS v. CALLAHAN · filed 2025-08-13

Because Plaintiff alleges that conduct forming the basis of his complaint took place six years ago in August 2019, his Section 1983 claim is barred by the statute of limitations.
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Section 2A:14-2 supplies a two-year limitations period for § 1983 claims in New Jersey.

Millan v. Municipality of Harrison · filed 2025-08-15

Under New Jersey law, the statute of limitations for a § 1983 claim is two years.
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Section 2A:14-2(a) supplies a two-year limitations period for § 1983 and New Jersey Civil Rights Act claims.

SOUTH v. SHAH · filed 2025-09-29(a)

Plaintiff's claims are based on § 1983 and the NJCRA, which cach have a two-year statute of limitations. ... (ciling N.J. Stat. Ann. § 2A:14-2(a)). ... The Court therefore dismisses the Complaint as untimely.
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Section 2A:14-2(a) bars a personal injury claim filed against a defendant more than two years after the cause of action accrues unless an exception applies.

Perez v. Rental Shop Holdings, LLC · filed 2025-10-15(a)

Based on our de novo review, we conclude plaintiff's personal injury complaint against Rental Shop is barred pursuant to N.J.S.A. 2A:14-2(a) because it was not filed within two years of the accrual of her cause of action .
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Section 2A:14-2 requires a personal injury action to be filed within two years after the claim accrues; a claim alleging delayed surgery accrued no later than the date of surgery.

BLAIR VS. CARE POINT HEALTH - CHRIST HOSPITAL (L-2744-18, HUDSON COUNTY AND STATEWIDE) · filed 2021-05-24

Thus, the only negligent action plaintiff complained of was the JCMC defendants' alleged failure "to intervene in a timely fashion." That cause of action clearly accrued no later than November 13, 2016, and the two-year statute of limitations therefore expired on November 13, 2018, well before plaintiff filed his amended complaint against the JCMC defendants.
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Section 2A:14-2’s personal injury limitations period is subject to New Jersey’s discovery rule.

Prince v. Trustees of University of Pennsylvania · filed 1968-02-29

Because of our conclusion that New Jersey would apply the discovery rule to this case, we find it unnecessary to determine the effect of New Jersey’s nonresident tolling provision.
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Section 2A:14-2’s two-year period for a medical malpractice claim may begin when the patient knew or had reason to know of the surgical injury and a cause of action based on it.

Yerzy v. Levine · filed 1970-01-15

In the context of the pleadings and in view of the facts developed thus far, Mrs. Yerzy and her husband should be afforded their opportunity to establish that Mrs. Yerzy first knew or had reason to know of defendant's severance of her common bile duct, and of the existence of a cause of action against him based thereon, within a period of two years prior to institution of her suit.
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Section 2A:14-2's two-year period for medical malpractice claims begins when the patient knows or should know of the injury and its causal relationship to negligent treatment, unless the delay would cause injustice.

Lopez v. Swyer · filed 1971-06-22

In other words, we believe the true rule in any medical malpractice case to be that a cause of action does not accrue until plaintiff is or should be aware of his injury and its causal relationship to the negligent treatment unless — as mandated by the inclusion of reference in the Yerzy affirmance to the "facts of this case" — the circumstance of delay suggests injustice will thereby be done.
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In a medical malpractice action, the two-year limitations period does not begin until the patient knows or reasonably should know that the injury may be attributable to the physician's fault.

Alfone v. Sarno · filed 1976-02-23

We have concluded that the phrase in the Lopez rule, "basis for an actionable claim," contemplates a combination of injury and fault. Both of these are elements of an actionable claim.
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Notes 151–300 of 479, oldest cases first.

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