N.J. Stat. Ann. § 2A:14-2

Section 2A:14-2 supplies a two-year limitations period for § 1983 claims brought in New Jersey.

MEARS v. C/O SMITH · filed 2025-09-11

The limitations period for Plaintiff’s claims is therefore two years.

Section 2A:14-2 sets a two-year limitations period for battery claims.

EDWARDS v. LINDENWOLD POLICE DEPARTMENT · filed 2025-09-25

The applicable statute of limitations for a battery claim is two years. See N.J. Stat. Ann. § 2A:14–2.

Section 2A:14-2(a) sets a two-year limitations period for personal injury actions.

Barrett · filed 2025-12-10(a)

New Jersey applies a two- year limitations period to personal-injury actions. N.J. Stat. Ann. § 2A:14-2(a). The accident occurred on July 13, 2022; thus, the two-year period expired in July 2024.

The two-year limitation period under N.J.S.A. 2A:14-2 may be shortened by agreement if the shorter period is reasonable and does not violate public policy.

Rodriguez v. Raymours Furniture Company, Inc. · filed 2014-06-19

Plaintiff next argues that because the courts of this State have determined that the appropriate statute of limitations for LAD claims and for common law claims of retaliatory discharge for filing a workers' compensation claim is two years, see Montells v. Haynes, 133 N.J. 282, 286 (1993); Labree v. Mobile Oil Corp., 300 N.J. Super. 234, 242 (App. Div. 1997), the two year limitation period provided by N.J.S.A. 2A:14-2 cannot be modified by agreement. Well-settled law is to the contrary.

Section 2A:14-2 supplies the two-year limitations period for Section 1983 actions in New Jersey.

Arezzo v. City of Hoboken · filed 2018-01-17

Because Arezzo’s Section 1983 claim accrued no later than September 19, 2012, we will affirm the trial court’s ruling that this action—filed almost four years later, on July 25, 2016—was untimely under the two-year statute of limitations for Section 1983 ... actions in New Jersey.

Section 2A:14-2(a) requires a personal injury suit to be filed within two years; a decedent’s estate does not receive a new two-year period under the Survivor Act.

Warren v. Muenzen · filed 2016-12-07(a)

Under the judge's construction of the 2009 Amendment, plaintiff's executor could file suit for the injuries sustained by plaintiff in the car accident nearly four years after the event, even though N.J.S.A. 2A:14-2(a) requires suit to be filed within two years.

Section 2A:14-2 bars a medical malpractice claim against a later-named defendant when the plaintiff failed to diligently identify that defendant before the limitations period expired.

WILLIAMS VS. ATLANTICARE REGIONAL MEDICAL CENTER,(L-2228-09, ATLANTIC COUNTY AND STATEWIDE) · filed 2017-05-11

We are also convinced the court correctly granted summary judgment on the separate, but equally dispositive, basis that plaintiff's claim against Costabile is barred by the statute of limitations, N.J.S.A. 2A:14-2.

Section 2A:14-2(a)'s two-year limitations period does not bar a germane counterclaim filed in the first responsive pleading when the plaintiff filed a timely complaint on the last day of that period.

VERONICA BARLEY VS. ARNELL D. BARLEY (L-6976-15, MIDDLESEX COUNTY AND STATEWIDE) · filed 2017-10-20(a)

The facts absent in Molnar are present here. Plaintiff's timely-filed complaint was pending when defendant filed her first responsive pleading asserting a germane counterclaim, and plaintiff delayed filing her complaint until the last day of the SOL, leaving defendant with no time within which to file a counterclaim before the running of the SOL. Under these ... circumstances, justice requires that defendant's germane counterclaim be saved from the SOL under the relation-back doctrine of Rule 4:9-3 or the tolling rationale.

A plaintiff must sue within two years of each discrete employment discrimination action; separate promotion denials do not form a continuing violation.

VIBHAKAR v. STATE OF NEW JERSEY (L-2276-16, MERCER COUNTY AND STATEWIDE) · filed 2022-07-06

Each of the employment actions listed by plaintiff was a discrete and separate occurrence. Therefore, plaintiff had to institute suit within two years of each allegation.

For a hostile work environment claim, the two-year limitations period begins with the last act in a continuing violation.

Hagel v. Davenport · filed 2024-02-06(a)

For a claim of hostile work environment, the limitation period begins to run from the occurrence of the last act in a pattern that establishes a unitary "continuing violation" comprising acts that would not be separately actionable even if timely.

Section 2A:14-2(a) gives LAD hostile work environment claims a two-year limitations period that runs from the last act of a continuing violation.

PORCARO VS. TOWNSHIP OF ROCHELLE PARK (L-5006-17, BERGEN COUNTY AND STATEWIDE) · filed 2021-11-16(a)

As our Supreme Court has instructed, "LAD claims are subject to the two-year statute of limitations set forth in N.J.S.A. 2A:14-2(a)" but "[d]etermining when the limitation period begins to run depends on when the cause of action accrued, which in turn is affected by the type of conduct a plaintiff alleges to have violated the LAD." Alexander v. Seton Hall Univ., 204 N.J. 219, 228 (2010). ... Also, given that the litany of plaintiff's allegations span "the course of her employment, from beginning to end [i.e., from August 2003 until December 2015], and even beyond," we are persuaded that for purposes of summary judgment, her cause of action would have accrued on the date on which the last act occurred, and her July 2017 complaint was therefore timely.

The two-year limitations period runs separately for each discrete retaliatory act, including a failure to promote; a later unrelated act does not extend the deadline.

RUIZ VS. BRIAN P. STACK MICHAEL FIGUEROA VS. THE CITY OF UNION CITY MARK JULVE VS. CITY OF UNION CITY JORGE A. P · filed 2019-03-15(a)

Inasmuch as a "discrete retaliatory or discriminatory act 'occur[s]' on the day that it 'happen[s],'" Morgan, 536 U.S. at 110; see also Roa, 200 N.J. at 567, the 2011 and 2012 claims – filed in July 2015, outside the two-year statutory timeframe – were properly dismissed.

The two-year limitations period for a LAD hostile work environment claim runs from the last act in a continuing pattern of harassment, even if earlier acts occurred outside that period.

MANSOUR VS. BROOKLAKE CLUB CORPORATION, INC., ETC. (L-4008-15, UNION COUNTY AND STATEWIDE) · filed 2019-07-10(a)

When a plaintiff alleges a pattern or series of acts, any one of which may not be actionable as a discrete act, but when viewed cumulatively constitute a hostile work environment, the cause of action accrues on the date of the last act, even if some of the component acts of the hostile work environment claim fell outside the two-year period. ... Accordingly, plaintiff's hostile work environment claim was timely as a continuing violation.

A LAD harassment claim cannot rely on the continuing violation doctrine to reach older acts when no discriminatory conduct occurred within the two-year limitations period.

TAYLOR-MUNGER VS. COUNTY OF UNION (L-2708-15, UNION COUNTY AND STATEWIDE) · filed 2019-07-15(a)

The statute of limitations for LAD claims is two years. ... Our review of the record, in light of the applicable legal standards, leads us to the same conclusion reached by the trial court: plaintiff did not raise a genuine issue of material fact on which a reasonable jury could conclude Burkert's alleged harassing behavior on any occasion after July 22, 2013, was motivated by plaintiff's race or gender. ... The trial court correctly dismissed plaintiff's complaint as time barred.

Section 2A:14-2 sets a two-year limit for intentional infliction of emotional distress claims, but a continuing pattern of tortious conduct may make earlier acts actionable if the claim is filed within two years of the last act.

M.J.L. v. S.N. · filed 2026-05-21

That is, although the limitations period for a tort claim is generally two years, N.J.S.A. 2A:14-2, the continuing violation doctrine provides "the entire claim may be timely if filed within two years of 'the date on which the last component act occurred,'" Alexander v. Seton Hall Univ., 204 N.J. 219, 229 (2010) (quoting Roa, 200 N.J. at 567). ... Given "the constant repetition" and "persistence" of plaintiff's wrongful acts, we are convinced the continuous tort doctrine permitted defendant to bring the IIED claim based on conduct occurring before February 2018. Morey, 94 N.J.L. at 430.

Section 2A:14-2 gives a plaintiff two years after a medical malpractice claim accrues to file suit; the discovery rule can delay accrual until the plaintiff knows or reasonably should know of a possible claim.

SOMERSET v. UNIVERSITY OF MEDICINE AND DENTISTRY OF NEW JERSEY · filed 2022-06-24

Medical malpractice actions, too, must be commenced within two years after the cause of action accrued. Fearon v. Corr. Med. Servs., Inc., No. A-4686-07T3, 2009 WL 395473, at *2 (N.J. Super. Ct. App. Div. Feb. 19, 2009) (citing N.J.S.A. 2A:14-2). ... It is undisputed that Mr. Somerset discovered his blindness by 2017 at the very latest and thus this action is untimely and must be dismissed.

Section 2A:14-2(a)’s two-year limit for personal injury actions does not govern a professional negligence claim against an insurance broker; that claim has a six-year limit.

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

The claims against Costello are separate from those asserted against the other defendants. Because plaintiff alleges professional negligence against the broker, those claims are subject to a six-year statute of limitations.

Section 2A:14-2 gives a person two years to bring an invasion-of-privacy claim based on intrusion on seclusion, measured from when the person discovered or reasonably should have discovered the claim.

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

“[C]laims for invasion of privacy based on intrusion on seclusion are subject to the two-year statute of limitations imposed by N.J.S.A. 2A:14-2.” ... Because Katz first brought this action on December 10, 2019, if Katz discovered, or with reasonable diligence should have discovered, that he might have a basis for his unjust enrichment and fraud claims before December 10, 2013, or his invasion of privacy claim before December 10, 2017, then these claims would be barred by the applicable statutes of limitations.

Section 2A:14-2 gives a Pierce wrongful discharge claim a two-year limitations period; notice of discharge is relevant to when that period begins.

MATEO v. FIRST TRANSIT INC. · filed 2021-08-30

For the reasons which follow, I conclude that Plaintiff has satisfied the statute of limitations under Pierce.

Section 2A:14-2 gives a tort-based wrongful discharge claim a two-year limitations period that begins when the employee is fired.

APPLEBAUM v. FABIAN · filed 2021-12-09

Viewed, as I think it must be, as a personal injury claim, the Pierce claim is subject to the two-year statute of limitations, which began to accrue the day she was fired. ... Because plaintiff was fired from THC in December 2013 and did not file this suit until 2018, her Pierce claim is time-barred.

Section 2A:14-2(a)'s two-year limitations period cannot be measured from the date an order was issued without determining when each plaintiff's claim accrued.

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

The court, however, erred by concluding counts one through seven are time-barred simply because the complaint was filed more than two years after the promulgation of the 2014 General Order.

A personal injury claim accrues when the plaintiff knows the injury may have been caused by another, even if the plaintiff does not yet know that party's identity.

RADZEWICK v. MHM WINDSOR, LLC (L-1254-17, MERCER COUNTY AND STATEWIDE) · filed 2022-08-01(a)

Applying these governing principles, we conclude that plaintiff's claims against Sherwin-Williams accrued no later than June 1, 2017, the date on which ... she filed her initial complaint.

Section 2A:14-2 sets a two-year limitations period for intentional infliction of emotional distress claims; dismissal is premature when the facts do not establish when the claim accrued.

GOULD v. JP MORGAN CHASE BANK, N.A. · filed 2021-09-21

In New Jersey, the statute of limitations for intentional infliction of emotional distress is two years. N.J.S.A. 2A:14-2. ... The statute of limitations is an affirmative defense, and the facts are not sufficiently clear at this point for me to dismiss Gould’s intentional infliction of emotional distress claim as time-barred.

Section 2A:14-2 gives claims for intentional infliction of emotional distress a two-year limitations period.

JAMAL v. ALLY FINANCIAL · filed 2024-12-27

Likewise, claims for “infliction of emotional distress are governed by the two-year statute of limitations contained in N.J.S.A. 2A:14–2.” Fraser v. Bovino, 721 A.2d 20, 25 (N.J. Super. App. Div. 1998). ... Since this lawsuit was not filed until February 15, 2024, roughly two and a half years after Plaintiffs were aware of the events their claims stem from, Count XI is time barred.

Section 2A:14-2(a) sets a two-year limitations period for intentional and negligent infliction of emotional distress claims.

HACKETT v. UNITED STATES DEPARTMENT OF JUSTICE · filed 2025-06-05(a)

Both IIED and NIED claims are subject to a two-year statute of limitations under New Jersey law.

Intentional infliction of emotional distress is a personal injury claim subject to the section's two-year limitations period.

Ramnanan v. Colin Keiffer, Esq. · filed 2025-10-24(a)

Generally, a personal injury claim "shall be commenced within two years next after the cause of any such action shall have accrued." N.J.S.A. 2A:14-2(a). ... Because intentional infliction of emotional distress claims are personal injury claims, they are governed by the two-year statute of limitations.

Section 2A:14-2(a) tolls the limitations period for suits brought by or on behalf of living minors, but not for suits brought on behalf of minor decedents or their estates.

SHENISE MONK v. KENNEDY UNIVERSITY HOSPITAL (L-3527-20, CAMDEN COUNTY AND STATEWIDE) (CONSOLIDATED) · filed 2022-07-14(a)

We hold N.J.S.A. 2A:14-2(a)'s minority tolling provision applies to suits brought by or on behalf of a minor and is inapplicable to suits brought on behalf of minor decedents or their estates, and the trial court erred in its application of minority tolling.

Section 2A:14-2(b) provides a two-year window to file otherwise time-barred claims for sexual crimes committed against minors.

C.P. v. the Governing Body of Jehovah's Witnesses · filed 2023-11-15(b)

Pertinent to this appeal is the enacted statute of limitations, which provided a two-year revival window for victims to file otherwise time-barred claims for sexual crimes committed against them while minors.

Section 2A:14-2’s two-year period for personal injury actions does not apply to false light invasion of privacy claims, which have a one-year limitations period.

Salve Chipola, III v. Flannery · filed 2025-08-07

Here, the parties dispute whether the appropriate limitations statute for the common law tort of false light is ... N.J.S.A. 2A:14-2, which applies to actions “for an injury to the person caused by the wrongful act, neglect or default of any person within this State” and mandates that such actions “be commenced within two years next after the cause of any such action shall have accrued.” ... We reject the notion that McGrogan and Rumbauskas are inconsistent, and we hold, as the Appellate Division held in Swan, that the one-year statute of limitations applies to false light claims.