42 Pa. Cons. Stat. § 5524

Section 5524(7) gives a breach-of-fiduciary-duty claim a two-year limitations period.

Koken v. Colonial Assurance Co. · filed 2005-10-07(7)

Alternatively a claim for breach of fiduciary duty is subject to a two-year statute of limitations. See Section 5524(7) of the Judicial Code, 42 Pa.C.S. § 5524(7) (two-year statute of limitations on actions for alleged fraud, which includes breach of fiduciary duty).

Section 5524(7) sets a two-year limitations period for breach of fiduciary duty claims under 15 Pa.C.S.A. § 1712.

Official Committee of Unsecured Creditors of National Forge Co. v. Clark (In Re National Forge Co.) · filed 2006-06-09(7)

Violations of § 1712 are likewise governed by a 2-year statute of limitations.

Section 5524(7) gives claims for breach of physician-patient confidentiality a two-year limitations period.

Burger v. Blair Medical Associates, Inc. · filed 2007-06-06(7)

We further hold this cause of action is governed by the two-year statutory period set forth in 42 Pa.C.S.A. § 5524(7), supra, not the one-year statutory period that governs causes of action sounding in an invasion of privacy.

Section 5524(7) gives claims sounding in deceit or fraud a two-year limitations period.

Lafferty v. Estep · filed 2011-05-19(7)

The statute of limitations for bringing a claim sounding in deceit or fraud is two years.

Section 5524(5)'s two-year limitations period governs private TCPA claims in Pennsylvania.

Weitzner v. Vaccess America Inc. · filed 2008-06-27(5)

The two-year Pennsylvania statute of limitations governs private TCPA claims with our Commonwealth.

Section 5524(7) gives a claim for breach of physician-patient confidentiality a two-year limitations period.

Burger v. Blair Medical Associates, Inc. · filed 2009-02-20(7)

Accordingly, we hold that a breach of physician-patient confidentiality is governed by Section 5524(7)’s two-year, default limitations period.

Section 5524(7) supplies the two-year limitations period for False Claims Act retaliation claims brought in Pennsylvania.

Campion v. Northeast Utilities · filed 2009-02-24(7)

The Court finds that the most closely analogous state limitations period which may be uniformly applied to claims under § 3730(h) is the residual statute of limitations for personal injury actions, in Pennsylvania, set forth in 42 Pa.C.S.A. § 5524(7).

Section 5524(7) sets a two-year limitations period for breach-of-fiduciary-duty claims.

O.E.M./Erie, Inc. Ex Rel. Schaffner v. McCallum (In Re O.E.M./Erie, Inc.) · filed 2009-06-03(7)

A cause of action for breach of a fiduciary duty is governed by Pennsylvania’s two year statute of limitations.

Section 5524(7) sets a two-year limit for breach-of-fiduciary-duty claims, but the Commonwealth is exempt from that limit under nullum tempus.

Commonwealth v. Citizens Alliance for Better Neighborhoods, Inc. · filed 2009-11-10(7)

Fumo is correct that a claim of breach of a fiduciary duty is subject to a two-year statute of limitations. Section 5524(7) of the Judicial Code, 42 Pa.C.S. § 5524(7).5 However, according to the doctrine of nullum tempus occumt reipu-blicae, meaning “time does not run against the republic,” the Commonwealth is exempt from statutes of limitations.

Section 5524(7) imposes a two-year limitations period on breach of fiduciary duty claims; the continuing violations doctrine requires an act breaching the duty within that period.

Langman v. KEYSTONE NAT'L BANK & TRUST CO. · filed 2009-11-23(7)

Because Jesse has failed to point to any specific facts in the record to show that the Wiener and Keystone Defendants committed any acts that would breach a fiduciary duty during the statute of limitations period, and because the continuing violations doctrine will not apply unless there is some such act during that period, we will grant defendants’ motion for summary judgment regarding Jesse’s claims for breach of fiduciary duty.

Section 5524 imposes a two-year limitation period on breach-of-fiduciary-duty claims.

In re Estate of Hernandez · filed 2010-09-01

First, any claims arising from transactions prior to May 13, 2006 are barred by the applicable two-year statute of limitations. 42 Pa.C.S. §5524, Maillie v. Greater Delaware Valley Health Care Inc., 156 Pa. Commw. 582, 590, 628 A.2d 528, 532 (1993) (claim for breach of fiduciary duty subject to two-year statute of limitations).

Section 5524 imposes a two-year limitations period on claims for professional negligence, fraudulent misrepresentation, fraudulent concealment, and fraud.

Perelman v. Adams · filed 2013-05-21

Plaintiffs tort claims—Count II for professional negligence, Count III for fraudulent misrepresentation, Count IV for fraudulent concealment, and Count V for fraud—are governed by a two year statute of limitations. See 42 Pa.C.S. § 5524 (2013).

Section 5524(7) gives Pennsylvania conversion actions a two-year limitations period.

Ardi Ltd. Partnership v. Buncher Co. (In Re River Entertainment Co.) · filed 2012-03-30(7)

In the alternative, there is no genuine dispute of material fact that ARDI’s conversion action is barred by the statute of limitations. Conversion actions in Pennsylvania are subject to a two year statute of limitations as set forth in 42 Pa.C.S.A. § 5524(7).

Section 5524(3)'s two-year limit applies to an action to recover mined coal because severed coal is personal property.

Robinson Coal Co. v. Goodall · filed 2013-07-29(3)

Since the coal in question is legally considered personal property, the trial court correctly applied the two-year statute of limitations.

Section 5524(7) imposes a two-year limitations period on conversion claims.

Herold v. Janus · filed 2013-12-03(7)

Conversion is an intentional tort that is constrained to a two-year statute *161of limitations in accordance with 42 Pa.C.S.A. §5524(7). ... Clearly, the two-year statute of limitations for the plaintiff’s conversion claim expired prior to suit being filed on February 26, 2013, and the same must be dismissed.

Section 5524(7) gives a negligence claim two years from accrual; later flooding does not restart that period.

Kowalski, B. v. TOA PA V, L.P. · filed 2019-03-27(7)

Accordingly, we agree with the trial court’s determination that any negligence claim became time-barred in 2009, when the two-year statute of limitations for negligence claims expired.

Section 5524(7) requires negligence, negligent misrepresentation, and fraud claims to be commenced within two years.

Dolan, L. v. Hurd Millwork Company, Inc. · filed 2019-06-21(7)

Actions sounding in negligence, negligent misrepresentation, and fraud must be commenced within two years.

Section 5524(2) sets a two-year limitations period for tort-based claims.

Soutner v. Covidien, LP. · filed 2019-08-13(2)

Under Pennsylvania law, the limitations period applicable to Plaintiffs’ tort-based ... claims is two years. See 42 Pa. C.S.A. § 5524(2).

Section 5524(7) requires a plaintiff to bring a tort claim within two years.

Tillman, K v. Wise, C. · filed 2020-04-13(7)

In Pennsylvania, a plaintiff must bring a claim sounding in tort within two years.

Section 5524(7) requires breach of fiduciary duty and fraud claims alleging tortious conduct to be brought within two years.

Est. of Rosemarie Monteverde, Appeal of: Adams, E. · filed 2020-02-12(7)

Pursuant to Section 5524(7), both claims allege tortious conduct and therefore “must be commenced within two years.”

Section 5524(3) sets a two-year limitations period for conversion claims, subject to the discovery rule.

Younkin, D. v. Beener, G. · filed 2020-02-27(3)

Moreover, the statute of limitations for a cause of action for conversion is two years. 42 Pa.C.S. § 5524(3). Thus without application of the discovery rule, Younkin’s conversion action would be barred by the statute of limitations.

Section 5524(7) gives a plaintiff two years to file a claim for damages founded on tortious conduct.

SCHWARTZ v. TAYLOR · filed 2021-03-11(7)

Here too, a two-year statute of limitations applies, 42 Pa. C.S.A. § 5524(7), and the statute of limitations was triggered on April 7, 2005 when Schwartz cross-examined Ludlam regarding Zucker’s role in Ludlam’s immunity agreement.

Section 5524(7) gives a breach of fiduciary duty claim a two-year limitations period that begins when the right to sue arises.

Rellick-Smith, S. v. Rellick, B. · filed 2020-03-31(7)

Rellick-Smith’s claim for breach of fiduciary duty is subject to a two-year statute of limitations which began to run when her right to institute the suit arose. See 42 Pa.C.S. § 5524(7); Mariner Chestnut Partners, L.P., 152 A.3d at 279.

Section 5524(7) gives a breach of fiduciary duty claim a two-year limitations period.

THE PR LIQUIDATING TRUST v. WESTERN LAND SERVICES, INC · filed 2021-03-30(7)

Under Pennsylvania law, the statute of limitations for a breach of fiduciary duty claim is two years, see 42 Pa. C. S. § 5524(7) (2013), and it generally “begins to run ... when the [fiduciary] openly and unequivocally violates his duties.” Weis–Buy Servs., Inc. v. Paglia, 411 F.3d 415, 422 (3d Cir. 2005).

Section 5524(7) applies a two-year limitation to common-law trademark infringement claims, but continuing infringement within the two years before suit may still be pursued.

LONTEX CORPORATION v. NIKE, INC. · filed 2021-02-24(7)

Therefore, even though Lontex’s Count IV was brought over two years after the initial discovery of the infringement, this claim is not barred in its entirety. Lontex’s Count IV, as it relates to Nike’s conduct during the two years preceding the filing of this lawsuit, may proceed.

Section 5524(7) requires claims of negligent or tortious conduct to be commenced within two years.

Prince, E. v. Uber Technologies · filed 2021-07-08(7)

In Pennsylvania, claims of negligent or tortious conduct must be commenced within two years. 42 Pa.C.S. § 5524(7).

Section 5524 imposes a two-year limitations period on the identified property and personal injury tort claims.

T.M. Bolick & E.B. Bolick v. Northeast Industrial Services Corp. · filed 2021-08-18(1)-(4), (7)

The Bolicks’ state law claims sounding in tort concerning their real and personal property (trespass, interference with enjoyment of real property, fraud and deceit, conversion, civil conspiracy) and for personal injury (battery) were subject to a two-year statute of limitations. 42 Pa.C.S. § 5524(1)-(4), (7).

Section 5524(7) gives negligence claims a two-year limitations period; the period can begin when the claimant knows of significant harm even if the full extent of the loss is unknown.

Pizzuti v. PA Ins. Dept. · filed 2022-03-04(7)

Trinity asserts, however, that Ms. Pizzuti filed her Petition for Review beyond the two-year statute of limitations for negligence claims and, thus, her claims against Trinity must be dismissed. See Section 5524(7) of the Judicial Code, 42 Pa. C.S. § 5524(7) (providing a two-year limitations period for “[a]ny . . . action or proceeding to recover damages for injury to person or property which is founded on negligent, intentional, or otherwise tortious conduct”). We agree. ... We conclude that the statute of limitations on Ms. Pizzuti’s negligence claims against Trinity began to run, at the latest, on November 8, 2018, when the MCARE Fund denied the Dunham Estate’s request for coverage. Ms. Pizzuti did not file her Petition for Review until June 25, 2021, well beyond the two-year limitations period. Therefore, we sustain this Preliminary Objection.

Section 5524(3) gives conversion claims a two-year limitation period; when conversion continues over time, the period may limit damages without barring the claim entirely.

Sugar Bowl Ranch, LLC v. SWN Production Company LLC · filed 2022-09-26(3)

In the absence of precise guidance from the Supreme Court of Pennsylvania, the Court concludes that the continuing violation theory applies to Plaintiffs’ conversion claims. Therefore, some of the damages Plaintiffs seek may be precluded by the two-year statute of limitations, but that is a matter to be determined as this matter progresses.

Section 5524(7) sets a two-year limitations period for negligence claims.

QIN v. STATE FARM FIRE AND CASUALY COMPANY · filed 2022-12-13(7)

As a negligence claim, Plaintiffs’ Count II against both State Farm and First American is subject to a two-year statute of limitations. 42 Pa. C.S.A. § 5524(7).

Section 5524(7) gives parties two years from accrual to bring claims for breach of fiduciary duty, negligence, or gross negligence.

Pompa v. St. Luke's Hospital · filed 2023-03-02(7)

Defendants do not contest that Pennsylvania applies a two-year statute of limitations to its counterclaims for breach of fiduciary duty, negligence, and gross negligence. ... Defendants filed their counterclaims on January 13, 2022, more than three years after those claims accrued. Thus, dismissal of Defendants’ claims for breach of fiduciary duty, negligence, and gross negligence is appropriate.

Section 5524(7) provides a two-year limitations period for tort and breach-of-fiduciary-duty claims.

Vitcavich, M. v. Owens Corning · filed 2023-08-22(7)

Further, it is beyond cavil that tort claims in Pennsylvania are subject to a two-year statute of limitations, as are claims for breach of fiduciary duty. 42 Pa.C.S. § 5524(7); see also Mariner Chestnut Partners, L.P. v. Lenfest, 152 A.3d 265 (Pa. Super. 2016).

Section 5524(2) and (7) provide a two-year limitations period for professional liability, medical malpractice, and personal injury claims in Pennsylvania.

COYLE v. MONTGOMERY COUNTY PENNSYLVANIA · filed 2023-03-20(2), (7)

As this court explained above, the statute of limitations to bring a professional liability/medical malpractice/personal injury claim in Pennsylvania is two years. See 42 Pa. C.S. § 5524(2), (7).

Section 5524(2) provides a two-year limitations period for personal injury claims, which also applies to Section 1983 claims in Pennsylvania.

Lawson v. PA. DOC · filed 2023-06-21(2)

The DOC Respondents also correctly observe that the statute of limitations governing personal injury claims applies to a Section 1983 action. See id. In Pennsylvania, that statute of limitations is two years. 42 Pa.C.S. § 5524(2); see also Urrutia, 91 F.3d at 457 n.9 (citing 42 Pa.C.S. § 5524(2)). ... For these reasons, we conclude that the bar of the statute of limitations is clear from the face of the Petition and bars all claims based on events occurring prior to December 28, 2019.

Section 5524 provides a two-year limitations period for negligence claims and supplies the limitations period for Section 1983 claims arising in Pennsylvania.

Small v. Lower Paxton Township · filed 2023-07-19

A two-year statute of limitations is applicable to Plaintiff’s Section 1983 and state law negligence claims.

Section 5524’s two-year limitations period applies to these tort claims, making them untimely when filed more than two years after tolling ended.

American Builders Insurance Company v. Keystone Insurers Group, Inc. · filed 2023-08-04

Accordingly, Pennsylvania’s shorter two-year statute of limitations applies to ABIC’s claims. As ABIC filed its original Complaint in August 2019, more than two years after September 14, 2015, its claims are untimely.

Section 5524(3) gives conversion claims a two-year limitations period.

JTH TAX LLC v. FOSTER · filed 2023-09-12(3)

Pennsylvania imposes a two-year statute of limitations on a cause of action for conversion. See 42 Pa. C. S. § 5524(3).

Section 5524(7) sets a two-year limit for actions seeking damages for injury to person or property based on tortious conduct.

Serota v. M.J. Mager ~ Appeal of: M. Serota · filed 2023-11-07(7)

Section 5524(7) of the Judicial Code provides a two-year statute of limitations for “[a]ny . . . action or proceeding to recover damages for injury to person or property which is founded on negligent, intentional, or otherwise tortious conduct . . . .”

Section 5524(2)–(3) sets a two-year limitations period for negligence, negligent hiring, and conversion claims.

Riad v. Wells Fargo Bank NA · filed 2023-12-15(2)–(3)

A two-year statute of limitations governs the tort claims—negligence, negligent hiring, and conversion. 42 Pa. C.S.A. § 5524(2)–(3).

Section 5524 sets a two-year limitations period for Pennsylvania claims involving assault, battery, false imprisonment, and intentional or negligent infliction of emotional distress.

MILLS v. CITY OF PHILADELPHIA · filed 2023-10-05(1), (7)

Mills’ state law claims—battery (Count II), assault (Count IV), false imprisonment (Count VI), conspiracy (Count XI), intentional infliction of emotional distress (Count XII), and negligent infliction of emotional distress (Count XIII)—are each subject to a two-year statute of limitations.

Section 5524(7) sets a two-year limit for personal-injury claims based on tortious conduct.

Tigue v. Pennsylvania State Police · filed 2023-10-30(7)

In Pennsylvania, a two-year statute of limitations governs personal injury claims, including claims for false arrest and imprisonment, malicious prosecution, malicious abuse of process, ineffective assistance of counsel, wrongful conviction and sentence, and Fourth Amendment and due process violations.

Section 5524(2) sets a two-year limitations period for personal injury and product liability claims in Pennsylvania.

HOYE v. ALLEGHENY COUNTY MEDICAL DEPARTMENT · filed 2023-10-30(2)

The applicable statute of limitations for personal injury and product liability claims in Pennsylvania is two years.

Section 5524 provides a two-year limitations period for civil rights violations.

C.L. Scheib v. Friedman · filed 2023-11-02

Furthermore, it is clear that any potentially applicable statute of limitations period has expired. Petitioner’s allegations are based on civil proceedings and various opinions and orders that occurred anywhere from 1997 to 2017. See Section 5523(1) of the Judicial Code, 42 Pa.C.S. § 5523(1) (one-year limitation for libel or slander) and Section 5524 of the Judicial Code, 42 Pa.C.S. § 5524 (two-year statute of limitation for civil rights violations).

Section 5524(7) provides a two-year limitations period for tortious interference and negligent misrepresentation claims; dismissal on limitations grounds requires the defense to be apparent on the complaint’s face.

FERDI, LLC v. J&J ASSET SECURISATION S.A. · filed 2024-01-11(7)

See 42 Pa. C.S. § 5524(7) (establishing a two-year statute of limitations). But “[a] complaint is subject to dismissal for failure to state a claim on statute of limitations grounds only when the statute of limitations defense is apparent on the face of the complaint.” Wisniewski v. Fisher, 857 F.3d 152, 157 (3d Cir. 2017) (citing Schmidt v. Skolas, 770 F.3d 241, 249 (3d Cir. 2014)). That is not the case here.

Section 5524 sets a two-year limitations period for Pennsylvania common law negligence and abuse of process claims.

ALIOTA v. MILLCREEK TOWNSHIP SCHOOL DISTRICT · filed 2024-03-27(1), (2)

As with Plaintiff's Section 1983 claims, the statute of limitations for the common law claims of negligence and abuse of process in Pennsylvania is two years. 42 Pa. C.S. §§ 5524(1), (2).

Section 5524 sets a two-year limitations period for assault, battery, intentional infliction of emotional distress, and negligence claims.

DELVAL v. TOWN OF MCCANDLESS · filed 2024-03-29(1), (2), (7)

Therefore, regardless of whether the court uses the dates of September 25, 2018, September 28, 2018, or October 21, 2018, plaintiffs' state law claims are barred by the applicable two-year statute of limitations because the Civil Complaint was filed more than two years after any of these dates.

Section 5524(3) requires a conversion claim involving personal property to be brought within two years of the taking or injury.

O'Connor, J. v. Snyder, E. and L. · filed 2024-05-07(3)

Therefore, any claim for conversion based upon the Snyders’ refusal began to accrue at that time. See Kingston Coal Co. v. Felton Min. Co., 690 A.2d 284, 288 (Pa. Super. 1997) (“The time period within which a litigant must file an action for conversion is delineated in 42 Pa.C.S. § 5524(3), which provides that ‘an action for taking, detaining, or injuring personal property, including actions for specific recovery thereof,’ must be commenced within two years of the taking or injury.”) (cleaned up).

Section 5524 imposes a two-year limitations period on tortious interference with contract claims under subsection (3) and fraudulent and negligent misrepresentation claims under subsection (7).

Keystone Alternatives LLC v. Athletes First, LLC. · filed 2024-06-21(3), (7)

Upon careful consideration of the amended complaint, the parties’ briefing, and relevant authority, the Court concludes that Plaintiffs’ tortious interference with contract and misrepresentation claims are barred by the relevant two-year statutes of limitations.

Section 5524(7) gives negligence claims, including gross negligence claims, a two-year limitations period.

OU v. FOUNDATIONS BEHAVIORAL HEALTH · filed 2025-03-27(7)

In Pennsylvania, the statute of limitations for actions sounding in negligence is two years. ... That includes those which are purportedly based upon gross negligence.

Section 5524(a)(3) sets a two-year deadline for actions involving the taking, detention, or injury of personal property, including a claim under the Landlord Tenant Act.

Zukos, S., Jr. v. Hui Zie, W. · filed 2025-05-06(a)(3)

Finally, we note that a two-year statute of limitations applies to a violation of the Landlord Tenant Act. See 42 Pa.C.S. § 5524(a)(3) (identifying “[a]n action for taking, detaining or injuring personal property, including actions for specific recovery thereof” as one that must be commenced within two years).

Section 5524(7) requires an action for property damage founded on tortious conduct to be commenced within two years; a failure to make a good faith effort to serve the complaint can leave the action time barred.

L. Gurdine (JK0623) v. Dailey · filed 2025-06-16(7)

Section 5524(7) of the Judicial Code provides an action to recover damages to property which is founded on negligent, intentional, or otherwise tortious conduct must be commenced within two years. ... We discern no error or abuse of discretion in Common Pleas’ conclusion that procedural difficulties did not justify Gurdine’s severe delay in serving Defendants.

Section 5524(7) requires an action for damages from negligent, intentional, or tortious injury to person or property to be commenced within two years.

Cruz v. SCI-Mercer Super. M. Adams · filed 2026-01-09(7)

Regarding the statute of limitations, under 42 Pa.C.S. § 5524(7), an “action or proceeding to recover damages for injury to person or property which is founded on negligent, intentional, or tortious conduct” must be commenced within two years. ... Here, we agree with DOC Respondents that Cruz’s action accrued on January 7, 2021, when Erie County Common Pleas denied his petition requesting an extension of time to file his PCRA petition. Accordingly, Cruz had two years from January 7, 2021, or until January 7, 2023, to commence this action.

Section 5524(7) sets a two-year limitations period for breach of fiduciary duty claims.

Dershaw, Trustee v. Nevels · filed 2025-01-15(7)

A two-year statute of limitations applies to Plaintiff’s claims arising from Mandle’s breaches of fiduciary duty.

Section 5524(3) gives a claimant two years to bring an action for taking, detaining, or injuring personal property, including a claim for property lost after an eviction.

Reiss, W. v. Hanchick, J. · filed 2026-03-12(3)

A two-year statute of limitations applies to a violation of the Landlord Tenant Act. ... As indicated above, Appellant’s cause of action would have accrued no later than July 25, 2020. As Appellant initiated the underlying action more than four years later, it is time-barred.

Section 5524(3) gives replevin and conversion claims a two-year limitations period.

Holmes v. City of Allentown · filed 2026-02-04(3)

The trial court did not err in applying the two-year statute of limitations under Section 5524(3) of the Judicial Code and concluding that Holmes’s replevin and conversion claims were time-barred.

Section 5524(3) imposes a two-year limit on claims for taking, detaining, or injuring personal property, including claims based on simple negligence.

Timco Engineering, Inc. v. Rex & Co., Inc. · filed 1985-02-25(3)

Turning now to Hobelmann’s statute of limitations argument, it is apparent that Timco’s claim is not time-barred only if it states a cause of action for common law fraud since Timco has not disputed that Pennsylvania’s two-year time bar would preclude claims based on simple negligence. ... In short, I conclude that Timco’s claims against Hobelmann are barred by the statute of limitations except insofar as Timco alleges fraud, but that Hobelmann is entitled to summary judgment on the merits of the fraud claim.

Section 5524(7) sets a two-year limitations period for fraud in the inducement and conspiracy to commit fraud claims.

Kreider, R. v. Correia, D., Oak Tree Real Estate · filed 2018-01-11(7)

Because the statute of limitations for these claims is two years, I need not look any further at their merits. See 42 Pa.C.S.A. § 5524(7).

Section 5524(7) sets a two-year limit for damages actions based on negligent, intentional, or other tortious conduct, including fraud.

TALLEY v. SAVAGE · filed 2022-12-08(7)

Pennsylvania’s two-year statute of limitations applies to these claims. 42 Pa. Cons. Stat. § 5524(7) (two-year statute of limitations applies to actions “to recover damages for injury to person or property which is founded on negligent, intentional, or otherwise tortious conduct or any other action or proceeding sounding in trespass, including deceit or fraud, except an action or proceeding subject to another limitation specified in this subchapter”). ... Accordingly, his fraud, civil conspiracy, emotional distress, and negligence claims are all time barred and must be dismissed.

Section 5524(3) imposed a two-year limitations period on fraudulent conveyance claims under Pennsylvania law before PUFTA took effect.

In Re Blatstein · filed 2000-01-21(3)

Despite these findings, we further note that limitations would bar any claims prior to February 1, 1994. ... Prior to that date, the state law which related to fraudulent conveyances was the Pennsylvania Uniform Fraudulent Conveyance Act, which had a statute of limitations of only two years.

Section 5524(3)’s two-year period does not govern a trustee’s action against a corporate shareholder for allegedly diverting corporate funds; that action falls under the six-year period in § 5527(6).

Zimmerman v. Rosenthal (In re Pasco Tobacco Co.) · filed 1982-08-03(3)

The defendant argues that the pertinent state statute of limitations is that found in § 5524(3) of title 42 of the Pennsylvania Consolidated Statutes. ... On first impression it appears that the section cited by the defendant is applicable herein because the complaint filed by the trustee can be characterized as an action to recover personal property (the funds of the bankrupt) wrongfully taken by the defendant. However, on examination of the legislative history to title 42, we conclude that the applicable statute of limitations in the instant case is the six-year statute cited by the trustee.

Section 5524(3) generally gives fraudulent conveyance actions a two-year filing period, but an action against corporate shareholders and directors under Pennsylvania’s Fraudulent Conveyance Act receives the six-year period of § 5527.

Doyle v. Lipoff (In Re Penn Packing Co.) · filed 1984-08-29(3)

Since an action under Pennsylvania’s Fraudulent Conveyance Act is essentially a tort we hold that such an action must generally be brought within the two-year bar of § 5524(3). ... Since the first cause of action in the controversy at bench is against stockholders and directors of a corporation but is predicated on the Pennsylvania Fraudulent Conveyance Law rather than the Business Corporation Law, we hold that the six year limitation of § 5527 applies.

Section 5524(3) sets a two-year limitations period for actions under Pennsylvania’s Fraudulent Conveyance Act.

Fidelity & Deposit Co. of Maryland v. Glenn (In Re Glenn) · filed 1989-10-16(3)

Actions brought under the Fraudulent Conveyance Act are governed by the two-year statute of limitations set forth at 42 Pa.C.S.A. § 5524(3) (Supp.1989).

Section 5524(7) imposes a two-year limitation period on Pennsylvania Uniform Fraudulent Conveyance Act claims that accrued after its 1982 enactment.

Shields v. Secretary of Veterans Affairs (In Re Shields) · filed 1993-01-08(7)

However, we also held that, as to a proceeding based upon the Pennsylvania UFCA, that the cause of action must have accrued within two years of the entry of the order for relief to avoid dismissal due to the statute of limitations arising from 42 Pa.C.S. § 5524(7), added to the Pennsylvania Judicial Code in 1982. ... Unfortunately for the Debtor, the applicable two-year limitation period had therefore already run as of the date of the filing of the Debtor’s bankruptcy case. The statute of limitations is therefore a complete defense to this action.

Section 5524(7) imposes a two-year limitations period on Pennsylvania fraudulent conveyance claims under the UFCA, even when the remedy sought is equitable.

Kaliner v. Load Rite Trailers, Inc. (In Re Sverica Acquisition Corp.) · filed 1995-03-23(7)

Thus, we find that the Trustee’s claim to avoid certain transfers of property of the Debtor on the basis of fraud under the UFCA is governed by the two year statute of limitations of 42 Pa. C.S.A. § 5524(7).

Section 5524(7) gives claims under the Pennsylvania Uniform Fraudulent Conveyance Act a two-year limitations period.

Reitmeyer v. Meinen (In Re Meinen) · filed 1999-03-26(7)

One such defense which defendants assert with respect to each of plaintiffs/Healey’s first five counts described above is the passage of the pertinent statute of limitations, which limitations period both parties correctly ascertain to be two years.

Section 5524(3) and (7) set a two-year limitations period for fraudulent conveyance actions under Pennsylvania law.

Gardner v. Tyson (In Re Gardner) · filed 1998-02-24(3), (7)

However, it is well-established that the limitations period for fraudulent conveyance actions under applicable Pennsylvania state law is the two-year period set forth in 42 Pa.C.S. §§ 5524(3) and (7).

Section 5524(3) imposed a two-year limitations period on fraudulent-conveyance claims under the law preceding PUFTA.

718 Arch Street Associates, Ltd. v. Blatstein · filed 2000-01-21(3)

Prior to that date, the state law which related to fraudulent conveyances was the Pennsylvania Uniform Fraudulent Conveyance Act, which had a statute of limitations of only two years. 42 Pa.C.S. § 5524(3); In re Frascatore, 98 B.R. 710, 718 (Bankr.E.D.Pa.1989); and In re Penn Packing Co., 42 B.R. 502, 505 (Bankr.E.D.Pa.1984).

Section 5524(7) gives a plaintiff two years to bring a fraud claim; the period begins when the plaintiff knows or reasonably should know of the injury and its cause.

McArdle v. Verizon Communications Inc · filed 2014-05-23(7)

In Pennsylvania, the statute of limitations for fraud claims is two years. 42 Pa. Cons. Stat. § 5524(7). ... Because McArdle’s fraud claim was not filed until August 27, 2013, it is barred by the statute of limitations.

Section 5524(7) sets a two-year limitation period for actions sounding in fraud.

ProtoComm Corp. v. Novell, Inc. · filed 1999-06-25(7)

The parties agree that the applicable statute of limitations under Pennsylvania law is 42 Pa.Cons.Stat. § 5524(7), setting a two year limitation period for actions sounding in fraud.

Section 5524(7) provides a two-year limitations period for fraud and negligent misrepresentation claims; dismissal is premature when the complaint does not reveal when that period began.

Lutz v. Rakuten, Inc. · filed 2019-04-22(7)

Because negligent misrepresentation and fraud are claims brought under Pennsylvania law, the applicable statute of limitations for these claims is two years. See 42 Pa. C.S.A. § 5524(7). ... In the instant matter, Rakuten Baseball raising the statute of limitations defense is premature because the face of Plaintiff's Complaint does not reveal when the limitations period began to run.

Section 5524(7) imposes a two-year limitations period on fraud claims.

Bennett v. Bank of America National Assoc. (In re Bennett) · filed 2015-05-12(7)

The statute of limitations for fraud under Pennsylvania law is two (2) years. 42 Pa.C.S. § 5524(7). The Debtor’s fraud claims have the same defects as the civil conspiracy claims. The Debtor lacks standing to sue for alleged frauds committed against Snyder and the applicable two (2) year statute of limitations has run.

Section 5524(7) imposes a two-year limitations period on claims for unfair competition and fraud.

A. Stucki Co. v. Buckeye Steel Castings Co. · filed 1991-06-19(7)

However, since plaintiff did not commence this action until March 14, 1988, more than four years after any action of Buckeye Steel which might give rise to liability under either of these theories, these state law claims would be time-barred under Pennsylvania law, which provides a two-year statute of limitations, as well as under Ohio law, which has a four-year statute of limitations. See 42 Pa. Cons.Stat. § 5524(7); Ohio Rev.Code § 2305.09(C).

Section 5524(7) sets a two-year limitation period for fraud claims.

McGrath v. Nationwide Mut. Ins. Co. · filed 2018-02-07(7)

Ohio law would therefore "borrow" Pennsylvania's two-year limitation period.

Section 5524 provides a two-year limitations period measured from accrual for claims governed by Pennsylvania’s personal injury deadline.

Ashford v. Crull · filed 2024-05-13

In Pennsylvania, this limitations period is two years from the date the cause of action accrued. 42 Pa. Cons. Stat. § 5524.

Section 5524(7) sets a two-year limitations period for fraud claims.

Ditech Holding Corporation · filed 2023-06-01(7)

Pennsylvania has a two-year statute of limitations for claims sounding in fraud.

Section 5524(7) imposes a two-year limitations period on fraud claims.

PARAMOUNT FINANCIAL COMMUNICATIONS, INC. v. BROADRIDGE INVESTOR COMMUNICATION SOLUTIONS, INC. · filed 2023-07-26(7)

Pennsylvania has a two-year statute of limitations on fraud claims. 42 Pa. Cons. Stat. § 5524(7). Plaintiffs filed this lawsuit on January 28, 2015; thus, for the claim to be time- barred, Broadridge must have proved that Mr. Miller knew or had constructive knowledge of the alleged fraud on or before January 28, 2013. Broadridge failed to meet this burden.

Section 5524(7) gives fraud claims a two-year limitations period that begins when storm warnings put the plaintiff on inquiry notice of possible fraud.

Prime Energy and Chemical LLC v. Arensberg · filed 2024-10-08(7)

Rather, a fraud claim’s two-year limitations period begins to run when a plaintiff is “put on inquiry notice by ‘storm warnings’ of possible fraud.”

Section 5524 does not cover common law fraud; the six-year limitations period applies.

Culbreth v. Simone · filed 1981-01-15

However, Section 5524 does not address fraud. A review of the legislative history of the Judiciary Act of 1976 does not reveal any intention by the legislature to change the common law fraud statute of limitations of six (6) years.

Section 5524(3) provides a two-year limitation period for fraud actions in Pennsylvania.

Fickinger v. C.I. Planning Corp. · filed 1982-12-30(3)

We have held that the limitation period of the Pennsylvania Securities Act does not apply and that § 5524(3) rather than § 5527(6) provides a two-year limitation period for fraud actions.

Section 5524(3)'s two-year period does not apply to federal securities fraud claims against nonseller defendants when the six-year common-law fraud period governs.

Eisenberg v. Gagnon · filed 1983-07-22(3)

One court in this district has applied the two year statute of limitations set out in 42 Pa.C.S.A. § 5524(3). ... Because the latest mandate by this circuit appears to require application of a six year limitation under appropriate circumstances, this court will continue to do so. As to W & C and P, W, C & M, then, a six year statute of limitation period applies.

Section 5524(3) applies a two-year limitations period to actions for negligent advice or fraudulent misrepresentation.

Sariego v. Gerber Products Co. · filed 1983-09-29(3)

Based on the same analysis of § 5524(3) and its policies, and based on our review of Tenney v. Dauphin Deposit Bank & Trust Co., supra, we hold that the two-year limitation period applies to Mrs. Sariego’s action against Gerber, whether it is viewed as an action for negligent advice or for fraud.

Section 5524’s two-year limitations period applied to common-law fraud before the 1982 amendment expressly included fraud.

A.J. Cunningham Packing Corp. v. Congress Financial Corp. · filed 1985-05-28(3)

This Court is of the opinion that section 5524(7) was added to section 5524 in order to clarify that deceit and fraud are actions in trespass which are therefore subject to the two year limitations period contained in section 5524.

Section 5524 provides a two-year limitations period for fraud-based UTP&CPL claims, beginning when the fraud is discovered.

Cramer v. Inter-County Hospitalization Plan Inc. · filed 1986-12-04

No specific statute of limitations is provided in the UTP&CPL, but, as cited earlier, the statute is intended to prevent fraud, Commonwealth v. Monumental, supra, and, therefore, the appropriate statute of limitations is the one for fraud generally, 42 Pa.C.S. §5524, pursuant to which the limitations period is two years. Fickinger v. C.I. Planning Corp., 556 F. Supp. 434 (E.D., Pa. 1982). This period begins to run once the fraud is discovered, Rothman v. Fillette, 503 Pa. 259, 469 A.2d 543 (1983), and, instantly, that discovery occurred no later than June 7, 1984, when plaintiffs were sent written denial of coverage of Mrs. Cramer’s medical bills.

Section 5524(7) imposes a two-year limitation on fraud claims, including a distinct fraud claim added by amendment.

Krause v. Great Lakes Holdings, Inc. · filed 1989-08-01(7)

The lower court determined that the proposed second cause of action against GL stated a cause of action for fraud which was barred by the two year statute of limitations. 42 Pa.C.S.A. § 5524(7). ... We agree with the lower court’s analysis. ... Since it appears from these prior pleadings that appellants were aware of the cause of action stated in the proposed second amended complaint in 1983, their proposal in 1987 to amend their complaint to state this separate cause of action is beyond the statute of limitations.

Section 5524(7)'s two-year limit applies to fraud claims that accrued after February 18, 1983, even if the alleged fraud occurred earlier.

Bhatla v. Resort Development Corp. · filed 1989-08-03(7)

The fact that the plaintiffs’ cause of action for fraud accrued in the spring of 1983 requires that the two-year statute of limitations, set forth in 42 Pa.C.S.A. § 5524(7), be applied. This two-year limitations period for fraud became effective on February 18, 1983.

Section 5524(7) applies a two-year limitation period to fraud claims.

Scalise v. LeTrent · filed 1990-09-11(7)

Instantly, plaintiffs have recognized their initial complaint is bottomed in fraud, and in our opinion it is inescapable the statute of limitations of two years is applicable.

Section 5524(7) gives common-law fraud claims a two-year limitations period that runs once the plaintiff knows of the alleged injury.

David Jeffrey Ltd. v. Lucente · filed 1990-09-19(7)

The statute of limitations for common-law fraud is two years. ... Defendants assert, and this court agrees, that plaintiff’s statement, that he was aware of the non-coverage at the time he initiated the first suit, combined with his testimony that he understood the policy to provide coverage for the losses he claimed, clearly establish that plaintiff knew of his alleged injury in 1986 and is therefore time-barred from bringing this claim.

Section 5524(7) imposes a two-year limitations period on common-law fraud claims.

Hallowell v. Lucente · filed 1991-10-29(7)

The plaintiff’s common-law fraud claims are beyond the two-year statute of limitations set forth by 42 Pa.C.S. § 5524(7).

Section 5524(7)’s two-year limitation applies to an equitable action to rescind an insurance policy for fraud if the action accrued after February 18, 1983.

United National Insurance v. J.H. France Refractories Co. · filed 1992-07-27(7)

Thus, read in conjunction, absent a specific definition of “action” applicable to § 5524(7), or a clear indication that a contrary definition of “action” was intended for § 5524(7), the two year limitations period applies to “any action [in law or equity], sounding in trespass, including fraud.” 42 Pa.C.S.A. § 5524(7).

Section 5524(7) gives fraud claims a two-year limitations period that begins when the injured party knows or reasonably should know of the injury and its cause.

Piezo Crystal Co. v. Uddeholm Corp. · filed 1994-08-18(7)

Piezo’s fraud claims are governed by a two year limitations period. ... Thus, if the injured party did not know of the injury or its cause despite exercising reasonable diligence, the limitations period does not begin to run until the party discovers or reasonably should have discovered the injury or its- cause.

Section 5524(7) imposes a two-year limitations period on fraud actions seeking damages for injury to person or property.

Toy v. Metropolitan Life Insurance · filed 2004-10-20(7)

An action to recover damages for injury to person or property which sounds in fraud is governed by a two-year statute of limitations.

Section 5524(7) imposes a two-year limitation period on fraud claims.

Global Industrial Technologies, Inc. v. Ash Trucking Co. (In Re Global Industrial Technologies, Inc.) · filed 2005-11-02(7)

In Pennsylvania, 42 Pa.C.S.A. § 5524(7) creates a limitation of two years for claims of fraud.

Section 5524(a)(7) gives fraud and deceit claims a two-year limitations period; the discovery rule does not toll that period once the plaintiff has enough facts to investigate the alleged wrong.

Cooney v. Booth · filed 2007-01-04(a)(7)

Pennsylvania imposes a two (2) year statute of limitations on tortious conduct, including deceit or fraud. 42 Pa. C.S.A. §5524(a)(7). ... Clearly Appellants were in possession of the critical facts necessary to prompt a further investigation of their fraud claims well before the two year statute of limitations period expired. There is simply no basis for application of the discovery rule here.

Section 5524(7) gives a conspiracy to defraud claim a two-year limitations period when its underlying claim is subject to that period.

Borough of Shippensburg v. Kelley · filed 2006-09-15(7)

The statute of limitations for conspiracy is the same as it is for the underlying action which forms the basis of the conspiracy. Ammlung v. City of Chester, 494 F.2d 811 (3d Cir. 1974). This would be two years under 42 Pa.C.S. §5524(7).

Section 5524(7) gives fraud claims a two-year limitations period, which also applies to a civil conspiracy claim based on fraud.

Balko v. Carnegie Financial Group Inc. (In Re Balko) · filed 2008-02-26(7)

The civil conspiracy alleged has as its basis the asserted fraud. Therefore, the applicable statute of limitations is that of fraud. The statute of limitations for fraud in Pennsylvania is two years pursuant to 42 Pa.C.S.A. § 5524(7).

Section 5524(7) gives Pennsylvania common law fraud claims a two-year limitations period.

McConnell v. K-2 Mortgage (In Re McConnell) · filed 2008-05-30(7)

The statute of limitations on common law fraud in Pennsylvania is two years. 42 Pa.C.S.A. § 5524(7).

Section 5524(7) gives a claimant two years to file a fraud or misrepresentation claim.

Atlantic City Electric Co. v. Estate of Riccardo · filed 2010-02-04(7)

Pennsylvania has a two-year statute of limitations in which to file a claim for fraud or misrepresentation.

Section 5524(7) gives a plaintiff two years to bring claims for fraud, misrepresentation, and negligent misrepresentation; a sewer backup that called for further inquiry did not toll that deadline.

Bobbett, C. v. Fosco, A. · filed 2014-12-03(7)

Likewise, Appellants had until July 11, 2007 to initiate an action concerning their claims of fraud, misrepresentation, and negligent misrepresentation. See id. at § 5524(7).

Section 5524 applies a two-year limitations period to intentional and negligent misrepresentation claims.

COHN v. PENNSYLVANIA STATE UNIVERSITY · filed 2020-02-12

Pennsylvania’s two-year statute of limitation also applies to Ms. Cohn’s intentional and/or negligent misrepresentation claim.

Section 5524(7) gives fraud claims a two-year limitations period; claims filed more than two years after the alleged fraud was discovered are time-barred.

GOK v. ROMAN CATHOLIC CHURCH · filed 2021-07-20(7)

It is also subject to a two-year statute of limitations, 42 Pa. C.S.A. § 5524(7), and a heightened pleading requirement. Fed. R. Civ. P. 9(b). ... In addition to their substantive pleading flaws,7 the first and second sets of fraud claims are time-barred on the face of the complaint (which was filed over two years after Plaintiff allegedly discovered the falsified documents).

Section 5524(7) gives fraud claims a two-year limitations period.

GOK v. POST & SCHELL PC · filed 2021-07-20(7)

It is also subject to a two-year statute of limitations, 42 Pa. C.S.A. § 5524(7), and a heightened pleading requirement. ... In addition to their substantive pleading flaws,7 the first and second sets of fraud claims are time-barred on the face of the complaint (which was filed over two years after Plaintiff allegedly discovered the falsified documents).

Section 5524(7) sets a two-year limitations period for fraud actions.

BAILEY v. NELNET STUDENT LOAN SERVICER · filed 2023-03-02(7)

In Pennsylvania, an action proceeding in fraud is governed by a two-year statute of limitations. 42 Pa. C.S. § 5524(7).

Section 5524(7) sets a two-year limitations period for fraud claims.

Gall, C. v. Gall, P. · filed 2023-03-27(7)

Ms. Gall’s second count is fraud, which has a two-year statute of limitations. See 42 Pa.C.S.A. § 5524(7).

Section 5524(7) gives fraud claims a two-year limitations period.

HOENIG v. NASCO HEALTHCARE, INC. · filed 2024-03-19(7)

Under Pennsylvania law, the statute of limitations for a fraud claim is two years. Plaintiff knew in 2017 that she was not receiving all of her commissions. She did not amend her Complaint to allege fraud until 2022, more than five years later. The fraud claim is therefore barred by the expiration of the statute of limitations.

Section 5524(7) requires claims based on deceit or fraud to be brought within two years.

Papapietro v. The Bank of New York Mellon · filed 2024-03-28(7)

Under Pennsylvania law, claims based on “deceit or fraud” must be brought within two years.

Section 5524(7) imposes a two-year limitation period on misrepresentation claims.

STULL · filed 2025-10-30(7)

Under Pennsylvania law, the applicable statute of limitations for the tort of misrepresentation is two years. Toy v. Metro. Life Ins. Co., 863 A.2d 1, 7 (Pa. Super. 2004), aff'd 928 A.2d 186 (Pa. 2007), citing 42 Pa. C.S.A. § 5524(7). Thus, based on the date this action was filed, February 8, 2022, Plaintiff would have to prove that she could not have been aware of the facts underlying her misrepresentation claim until sometime after February 8, 2020. This she cannot do.

Section 5524(7) gives fraud claims a two-year limitations period.

Marin v. Pittsburgh Tribune Review · filed 2017-07-10(7)

While, ... at the time of the District Court’s December 5, 2016 orders, the one-year limitation on Marin’s defamation claim had run, the two-year limitation for his fraud claim had not.

Section 5524’s two-year period for subsurface injury claims runs from discovery of the cause of harm or when it reasonably should have been discovered; disputed questions about reasonable discovery are for the jury.

McNay v. Gateway Coal Co. · filed 1991-04-09

However, as pointed out by the Pennsylvania Supreme Court in the Smith case and by Judge Weber in the Pennzoil Co. ca.se, what is a reasonable period during which plaintiffs should have discovered their cause of action is a factual determination to be made not by this court but by the jury.

Section 5524(7)’s two-year period for a bad-faith claim is not tolled when the insurer provides information requested by law enforcement but does not initiate the criminal investigation.

Fieldhouse, D. v. Metropolitan Property · filed 2016-06-21(7)

As a result, we conclude that Jones applies to this case, Diamon does not, and the statute of limitations was not tolled.

Section 5524(2)’s two-year period for personal injury claims is not tolled by fraudulent concealment when the defendant merely fails to answer pre-litigation correspondence and has no duty to disclose the incident date.

Busciacco, D. v. Acme Markets, Inc. · filed 2016-11-15(2)

The record plainly shows that Acme took no affirmative action; it simply did not respond to Appellant’s pre-litigation correspondence. Further, Appellant has not shown that Acme was under a duty to provide him with the correct date, especially when Appellant’s discovery requests had not yet been served. As such, we conclude that the record, viewed in the light most favorable to Appellant, does not establish fraudulent concealment. Because we determine that the fraudulent concealment exception does not apply to this matter, the statute of limitations was not tolled.

Section 5524(2) gives two years to bring a negligence-based death claim; fraudulent concealment does not toll that deadline unless the plaintiff pleads facts supporting it.

Gorski v. v. Colton, A., M.D. · filed 2017-01-05(2)

Indeed, since decedent died on June 28, 2008, any medical negligence actions arising from her death had to have been filed by June 28, 2010. ... Although, here, Gorski issued a general denial of Dr. Miller’s affirmative defense, he did not include any facts supporting application of the doctrine of fraudulent concealment in any of the relevant pleadings.

Section 5524(7) gives fraud claims a two-year limitations period that is tolled until the plaintiff learns or, through due diligence, reasonably should learn of the claim.

Beauty Time Inc v. VU Skin Sys Inc · filed 1997-07-03(7)

Therefore, we conclude that the discovery rule applies in Pennsylvania when the underlying cause of action sounds in fraud, and that the statute of limitations is tolled until the plaintiff learns or reasonably should have learned through the exercise of due diligence of the existence of the claim.

Section 5524(2) gives personal injury and wrongful death claims a two-year limitations period, subject in latent disease cases to a discovery rule that runs the period when the plaintiff knows or reasonably should know of the injury and its connection to another party’s conduct.

Debiec v. Cabot Corporation · filed 2003-12-08(2)

Pennsylvania has a two year statute of limitations for personal injury and wrongful death actions. 42 Pa. Cons. Stat. § 5524(2). ... Latent disease cases often implicate this so-called "discovery rule," which tolls the statute. In this type of case, "the statute of limitations begins to run ... when the plaintiff knows, or reasonably should know: (1) that he has been injured, and (2) that his injury has been caused by another party's conduct." Cathcart, 471 A.2d at 500.

Section 5524(7) gives negligence claims a two-year limitations period; under the discovery rule, awareness of the injury triggers a duty of diligent inquiry even if the claimant does not yet know the details of the alleged negligence.

Cumis Insurance Society, Inc. v. Citibank · filed 1996-03-31(7)

Pennsylvania law provides a two year statute of limitations for negligence. ... Benchmark was aware of its injury and was under a duty under Pennsylvania law to make a diligent inquiry to determine the details of any cause of action it may have had.

Section 5524(2) gives two years to bring a personal injury claim, with the discovery rule delaying the period until the plaintiff knows or reasonably should know of the injury and its cause.

Vitalo v. Cabot Corporation · filed 2005-03-03(2)

If, however, an injury is undiscovered (that is, it is hidden and therefore unknown or latent), the time within which to sue does not begin to run until the plaintiff first knows, or reasonably should know, that s/he has been injured and that her/his injury has been caused by another party's conduct.

Section 5524(2) gives a plaintiff two years to bring a personal injury claim, subject to the discovery rule when the injury could not be discovered through reasonable diligence.

Vitalo v. Cabot Corp. · filed 2005-03-03(2)

Our opinion in Debiec described the applicable Pennsylvania state law at issue here, namely, Pennsylvania’s two-year statute of limitations for personal injury and wrongful death actions, 42 Pa.Cons.Stat. § 5524(2), and its associated “discovery rule,” which delays the running of the limitations period when “a party, through no fault of his or her own, does not discover her injury until after the statute of limitations normally would have run.” 352 F.3d at 129.

Section 5524(7)’s two-year limitations period is tolled by the discovery rule until a plaintiff discovers or reasonably should discover the injury and claim; plausible allegations that the injury could not be discovered through reasonable diligence can defeat dismissal.

Brandow Chrysler Jeep Co. v. DataScan Technologies · filed 2007-06-13(7)

The discovery rule tolls the statute of limitations until plaintiffs discover or reasonably should discover the injury and claim. ... The facts alleged in the complaint regarding plaintiffs’ reliance on DataScan’s audit information can be reasonably interpreted to show that plaintiffs were unable to discover the injury until the audit summary reported for July 2004. Therefore, I will not grant defendant’s motion to dismiss Counts Two, Three and Four on the basis of the statute of limitations.

Section 5524(7) gives tortious interference and fraud claims a two-year limitations period that may be tolled under the discovery rule when reasonable discovery of the injury is factually disputed.

Bral Corp. v. Johnstown America Corp. · filed 2013-01-22(7)

Under Pennsylvania law, the relevant statute of limitations on claims of either tortious interference or fraud is two years. ... As such, this Court finds that there indeed does' exist a genuine dispute as to material facts that would determine whether the discovery rule applies in this case.

Section 5524(2) sets a two-year period for personal injury actions; the discovery rule can toll it until the plaintiff knows or reasonably should know of the injury and its cause, and disputed notice facts can preclude a time bar as a matter of law.

Rowland v. Novartis Pharmaceuticals Corp. · filed 2014-07-28(2)

Pennsylvania law prescribes a two-year limitations period for personal injury actions. 42 Pa. Cons.Stat. § 5524(2). ... That is not sufficient evidence for the Court to rule as a matter of law that the statute of limitations precludes Mr. Orr’s claim.

Section 5524(2)'s two-year limitations period may be tolled under Pennsylvania's discovery rule until the claimant reasonably could learn of the injury and its cause.

Estate of Tyler ex rel. Floyd v. Grossman · filed 2015-06-11(2)

Given these circumstances, the Court concludes that the discovery rule should apply to toll the statute of limitations until July 30, 2014. And given that the Estate filed its Complaint on August 26, 2014, less than one month later, the due process claims are timely.

Section 5524(7) sets a two-year limitations period for fraud and negligent misrepresentation claims, subject to tolling under Pennsylvania’s discovery rule.

Jacobs v. Halper · filed 2015-07-22(7)

Under Pennsylvania law, fraud and negligent misrepresentation have a two-year limitations period, see 42 Pa. Cons.Stat. § 5524(7); in New York, the statutory limitations period for both claims is six years, see N.Y. C.P.L.R. § 213. ... Accordingly, the Court finds that, as in New York, the Pennsylvania discovery rule applies to toll Plaintiffs claims until June 2013, when Plaintiff was informed that the Mays Travel Bag and Mays Jersey were inauthentic.

Section 5524(2) gives a plaintiff two years to bring a design defect claim, with the discovery rule tolling that period while the injury or its cause is neither known nor reasonably ascertainable.

Adams v. Zimmer US, Inc. · filed 2019-11-20(2)

In Pennsylvania, a prospective plaintiff has two years to bring a design defect claim like Adams’s. See 42 Pa. Cons. Stat. § 5524(2). The two-year statute of limitations generally begins to run “when an injury is inflicted.” Wilson v. El-Daief, 964 A.2d 354, 361 (Pa. 2009). But “where the plaintiff’s injury or its cause was neither known nor reasonably ascertainable,” the “discovery rule” tolls the statute of limitations.

Section 5524 gives negligence claims a two-year limitations period, subject to the discovery rule when reasonable minds could differ about when the plaintiff knew or should have known of the injury and its cause.

REGIONAL PRODUCE COOPERATIVE CORPORATION v. TD BANK, N.A. · filed 2020-03-24

Under Pennsylvania law, the statute of limitations for claims of negligence is two years. See 42 Pa. Cons. Stat. § 5524. ... Taking these facts as true, as I must at the motion to dismiss stage, I find that reasonable minds could differ as to when Plaintiff, exercising diligence, knew or should have known of the injury and its cause.

Section 5524(7) gives Pennsylvania §1983 claims a two-year limitations period, which is tolled while the PLRA requires exhaustion of administrative remedies.

DISCO v. THOMPSON · filed 2020-04-07(7)

The Court observes that a Pennsylvania §1983 plaintiff’s claim is subject to the ... Commonwealth’s personal injury statute of limitations which requires that an action be brought within two years of accrual of the claim (e.g., of a plaintiff’s becoming aware of the allegedly unconstitutional acts). 42 Pa. Cons.Stat. § 5524(7). However, this Circuit has expressly held that the Prison Litigation Reform Act of 1995 (the “PLRA”), which requires that a prisoner exhaust administrative remedies prior to filing a §1983 claim, creates “a statutory prohibition that tolls Pennsylvania’s statute of limitations”. Pearson v. Sec'y Dep't of Corr., 775 F.3d 598, 603 (3d Cir. 2015). Defendants’ unsupported assertion of grounds for dismissal is therefore without merit.

Section 5524 supplies a two-year limitations period for Pennsylvania § 1983 claims, subject to the discovery rule when the plaintiff could not yet know the facts supporting a municipal policy claim.

Kirksey v. Ross · filed 2019-04-12

In Pennsylvania, the length of the statute of limitations for a § 1983 claim is two years. ... In Pennsylvania, the discovery rule operates to delay the running of the statute of limitations. ... Given that the application of the discovery rule turns on a factual inquiry, the answer to which is not apparent on the face of the complaint, this case should proceed to discovery, and the City can explore when these plaintiffs learned or should have learned of the predicate facts necessary to know that they had a cause of action against the City.

Section 5524(2)’s two-year period for negligence and product liability claims begins when the plaintiff knew or reasonably should have known of the injury.

Tily v. Ethicon, Inc. · filed 2020-09-08(2)

The limitations period began to run on Plaintiff’s negligent and product liability claims when she either knew, or reasonably should have known, of her alleged injuries.

Section 5524’s two-year limitations period can begin before an injured plaintiff learns that the product causing the injury was defective.

Russell v. Ethicon, Inc. · filed 2020-10-09

At the outset, the Court rejects Plaintiff’s contention that she must have known about the product’s defects to trigger the statute of limitations.

Section 5524 sets a two-year limitations period for Pennsylvania § 1983 claims; a plaintiff seeking the benefit of the discovery rule must present evidence of reasonable diligence in learning the basis for the claim.

KIRKSEY v. ROSS · filed 2021-11-08

In Pennsylvania, the length of the statute of limitations for a § 1983 claim is two years. Id. (citing 42 Pa. Cons. Stat. § 5524). ... Because Kirksey offers no evidence to support the application of the discovery rule to her claim, the Court finds that no reasonable jury could find that the discovery rule applies here.

The two-year Pennsylvania personal-injury limitations period applies to § 1983 claims and may be equitably tolled when diligent filing is prevented by circumstances beyond the plaintiff’s control.

ROJAS v. NEWMAN · filed 2021-06-11(2)

The length of the statute of limitations for a § 1983 claim is governed by the personal inj ury tort law of the state where the cause of action arose, which in Pennsylvania is two years. ... Based on the foregoing, the Court concludes Rojas is entitled to equitable tolling. Rojas diligently and repeatedly attempted to assert his claims at the proper time, only to be thwarted by mailing issues beyond his control.

Section 5524(7) gives Pennsylvania fraud claims a two-year limitations period, with the discovery rule delaying the start until the plaintiff discovers or through due diligence should discover the facts underlying the claim.

needle v. T Rowe Price Group Inc. · filed 2022-08-15(7)

Claims of fraud under Pennsylvania law9 are governed by a two-year statute of limitations. 42 Pa. Cons. Stat. § 5524(7). ... Here, the statute of limitations clock began ticking when Plaintiffs discovered—or should have discovered, through due diligence—the facts underlying their fraud claim against Dosik.

Section 5524’s two-year limitations period is not delayed by the discovery rule when a claimant fails to exercise even minimal diligence in investigating the injury.

BRETTER v. PEYTON · filed 2024-08-12

Lacking evidence that they exercised even minimal diligence, Plaintiffs cannot find shelter in the discovery rule.

Section 5524 gives state tort claims a two-year limitations period, and the Heck delayed accrual rule does not apply to those claims.

GORDON v. LICIARDELLO · filed 2024-07-25

Gordon’s state law tort claims are subject to a two-year statute of limitations. 42 Pa. Cons. Stat. § 5524. ... Given no Pennsylvania court has so ruled, the Heck delayed accrual rule does not apply to Gordon’s state law claims.

Section 5524(2)’s two-year period begins when the plaintiff knows or reasonably should know of the injury and its likely cause.

Swasing v. Leis · filed 1980-05-28(2)

In our opinion, plaintiff clearly ascertained both the existence of her condition and the likely cause of that condition no later than April 15, 1977. Since the action was not initiated until July 6, 1979, it is barred by the running of the statute of limitations.

Section 5524(2)’s two-year limit may require a jury to decide when a plaintiff reasonably should have discovered an injury’s cause.

Anthony v. Koppers Co., Inc. · filed 1980-11-07(2)

In the present cases the lower court ruled that summary judgment for appellants was inappropriate because there was a genuine issue as to when appellees reasonably should have discovered the causal connection between the coke oven emissions and the decedents’ lung cancer. We agree. In many cases, perhaps in most, the issue of what a plaintiff reasonably should have discovered is not a question that may be resolved as a matter of law at the summary judgment stage but instead is a question for the jury.

Section 5524’s limitations period may be tolled when a plaintiff alleges and proves reasonable efforts to discover the facts underlying the claim and explains why they could not be discovered sooner.

Bickell v. Stein · filed 1981-09-25

The plaintiff has the burden of justifying any delay beyond the date on which the limitation would have expired if computed from the date on which the acts giving rise to the cause of action allegedly occurred. He must allege and prove facts which show that he made reasonable efforts to protect his interests and which explain why he was unable to discover the operative facts for his cause of action sooner than he did.

Section 5524(2)’s two-year period for medical malpractice begins when the plaintiff discovers or should have discovered the injury.

Stein v. Richardson · filed 1982-07-16(2)

Thus, the decisional law in Pennsylvania since Ayers has consistently held that the statute of limitations does not commence to run until the plaintiff discovers or should have discovered his injury.

For injuries or diseases whose causes are not readily apparent, the two-year period begins when the plaintiff knew or had reason to know of the injury, its operative cause, and the causal relationship between them.

Neal v. Carey Canadian Mines, Ltd. · filed 1982-08-31(2)

With respect to injuries or disease for which the causes are not readily apparent, the statute of limitations does not begin to run against the prospective plaintiff until such time that plaintiff either knew or had reason to know of the injury, the operative cause of the injury, and the causal relationship between the injury and the operative conduct. ... Although Dr. Labowski’s testimony sufficiently establishes that Mr. Hojnacki knew that he suffered from a chronic lung condition prior to November 28, 1976, the Court finds that his testimony does not overwhelmingly establish that Mr. Hojnacki knew or had reason to know of the operative cause of his injury—that of exposure to asbestos fiber at the Philip Carey plant.

Section 5524(2)'s two-year period does not wait until an injured plaintiff discovers who manufactured the products that caused the injury.

Staiano v. Johns-Manville Corp. · filed 1982-09-03(2)

We find no reason to postpone the commencement of the statute until a plaintiff has in addition discovered who manufactured the products that he knows have injured him.

Section 5524(2)’s two-year period may begin later under the discovery rule if reasonable diligence would not have revealed the causal relationship between the injury and the defendant’s conduct.

Petri v. Smith · filed 1982-10-22(2)

We cannot say that as a matter of law the appropriate standard of reasonable diligence required more of appellant in this case, nor can we say that it is dear that reasonable men could not differ as to what the appropriate standard required of her. A jury could conceivably conclude that her failure to investigate the possible causes of Kenneth’s condition until 1977 was reasonable, given her religious beliefs, her difficult pregnancy and her prior conversations with Kenneth’s pediatricians.

Section 5524(4)’s two-year period is tolled until the plaintiff reasonably discovers the injury and who caused it.

Pocono International Raceway Inc. v. Pocono Produce Inc. · filed 1983-02-07(4)

We hold that the statute of limitations in this case was tolled until that date where the appellant reasonably ascertained that its tunnel had been damaged by appellee.

Section 5524(2)’s two-year period for a medical malpractice claim begins when the plaintiff has enough information to investigate the injury’s cause with reasonable diligence.

DeMartino v. Albert Einstein Medical Center · filed 1983-04-29(2)

We, therefore, find that the conversation of May 1977 with Dr. Brothman produced sufficient information to satisfy the Volpe test and trigger the statute of limitations against appellant’s medical malpractice claim.

For wrongful-death and survival claims, § 5524(2)’s two-year period begins when the injured person knows or reasonably should know the injury’s cause, but no later than death.

Redeker v. Johns-Manville Products Corp. · filed 1983-09-28(2)

We believe, based on the foregoing, that the Pennsylvania Supreme Court will read the statute in the light of the existing, and now well-established, law of Pennsylvania relative to the application of the discovery rule to personal injury actions and conclude that the statute commences to run when the victim had, or reasonably should have had, the knowledge set forth by the Superior Court in Anthony, 425 A.2d at 436, but commences at the latest on the death of the victim, so that all actions must be brought within two years of that date at the latest.

Section 5524(4)’s two-year period for trespass to real property is tolled under the discovery rule only when reasonable diligence could not reveal the injury or its cause.

Pocono International Raceway, Inc. v. Pocono Produce, Inc. · filed 1983-12-12(4)

In the present case, as a matter of law, the cause of action was discoverable by the exercise of diligence in the use of means within reach of the Raceway, and, as such, no equitable exception to the statutory limitation is warranted.

Section 5524(2)'s limitation period for a wrongful death claim begins when the plaintiff discovers, or reasonably should discover, facts on which to base the claim.

Richardson v. LaBuz · filed 1984-04-10(2)

Where, as here, the discovery rule applies, the statute of limitations does not begin to run until the plaintiff discovers, or reasonably should discover, facts on which to base a cause of action. Therefore, the cause of action accrues on the date of discovery.

Section 5524’s two-year period applies to negligent building-construction claims under the discovery rule; damage that puts an owner on notice of a widespread defect starts the period even if different units are damaged later.

National Housing Partnership v. Barness · filed 1984-08-29

We believe the better reason and correct result is that which applies the “discovery rule,” which rule has been employed in actions seeking recovery for negligent building construction, and is not limited to the better-known examples of personal injury actions. ... Nonetheless, we are persuaded that virtual identity of the particular units damaged in the two occurrences is not necessary, since what transpired earlier was certainly sufficient to have put a reasonable and prudent building owner on notice as to a construction defect which apparently pervaded the entirety of the housing complex.

Section 5524(2)’s two-year period for a No-Fault Act tort claim begins when the claimant knows or, with reasonable diligence, should know that medical or dental losses exceed the Act’s threshold.

Bond v. Gallen · filed 1983-12-30(2)

We hold that the two-year statute of limitations on tort actions allowed by the No-Fault Act does not begin to run until the claimant knows or, exercising reasonable diligence, should know that the claimant’s medical and/or dental losses exceed a threshold specified in Section 301(a) of the Act.

Section 5524’s two-year period does not begin to run until the No-fault Act’s threshold requirements are met when the plaintiff proceeds under that Act.

Diggan v. Diggan · filed 1984-10-04

In this case, however, plaintiff chose to proceed under our No-fault Act, and so, is entitled to the extended limitations period provided under Bond v. Gallen, supra.

Section 5524(2)'s two-year limitations period does not restart when a new injury or complication appears after the plaintiff discovers the initial injury.

Caldwell v. A.H. Robins Co. · filed 1984-01-09(2)

However, the plaintiff is not entitled to a new limitations period to begin with the appearance of each new injury or complication.

The two-year personal injury limitations period can begin before the plaintiff knows that someone is legally culpable.

Berardi v. Johns-Manville Corp. · filed 1984-10-05(2)

This court specifically rejected the argument that the plaintiff must know that he has a cause of action, i.e., that someone is legally culpable, — before the statute of limitations begins to run.