42 Pa. Cons. Stat. § 5525

Section 5525 gives a plaintiff four years to bring a breach of contract claim; when the breach date is unclear from the complaint, timeliness cannot be resolved on a motion to dismiss.

Certain Underwriters of Lloyd's of London v. Koch Corporation · filed 2025-01-13

Thus, determining whether the four-year statute of limitations had run would require a fact-intensive inquiry that is not appropriate at this stage of the litigation.

Section 5525 sets a four-year limitations period for breach of contract actions.

Colonial Assurance Co. v. Mercantile & General Reinsurance Co. · filed 2003-12-10

Under Pennsylvania law, the statute of limitations for breach of contract is four years. 42 Pa.C.S.A. § 5525. Therefore, the outermost limit of the statute of limitations applicable to the liquidator for a breach of contract action is six years four years plus two years from the time of the order of liquidation. This period expired in the late 1980s. By the time the instant case was filed in 2003, the time within which to file this action had long expired.

Section 5525 gives a plaintiff four years to bring a breach of contract claim; the period can begin once the plaintiff is on notice of the need to investigate the claim.

Perelman v. Adams · filed 2013-05-21

Plaintiffs Count I breach of contract claim is governed by a four-year limitations period. See 42 Pa.C.S. § 5525 (2013). ... Given the circumstances, the limitations period to bring Counts II through V therefore would have expired in 2009, and the period to bring Count I would have expired in 2011.

Section 5525’s four-year limitation period applies to a debt collection suit when Pennsylvania law governs, and bars a suit filed after that period.

Jackson v. Midland Funding, LLC · filed 2010-12-10

Because this Court holds that the four-year Pennsylvania statute of limitations applies to the underlying suit, the suit was time-barred.

Section 5525 requires a breach of contract claim to be brought within four years of the breach.

Electroplating Technologies Ltd. v. HH Sumco Inc. · filed 2009-09-24

Under Pennsylvania law, claims for breach of contractual obligations must be brought within four years of the breach. 42 Pa. C.S. §5525; see Wachovia Bank N.A. v. Rosen, 2004 WL 1593644, *1 (Pa. Com. Pl. 2004). ... ETL did not commence this action until July 2005, over four-and-one-half years after the alleged breach. Consequently, the court finds that ETL’s claim that Sumco breached contractual obligations under the in*167terim license agreement by excluding Forand from those trials violated the statute of limitations and was untimely filed.

Section 5525(8)’s four-year period for actions on written contracts does not apply when the claim sounds in tort and the agreement is collateral to the cause of action.

Harleysville Homestead, Inc. v. Lower Salford Township Authority · filed 2009-08-28(8)

Accordingly, Harleysville claim sounds in tort and the Agreement itself is collateral to Harleysville’s cause of action. Therefore, the four year statute of limitations is inapplicable.

Section 5525(8) sets a four-year limitations period for contract actions, which the court applies to an ERISA benefits claim.

Minnis v. Baldwin Bros Inc · filed 2005-08-18(8)

In Pennsylvania, the statute of limitations for contract actions is four years. See 42 Pa. C.S.A. § 5525(8).

Section 5525(8)’s four-year limitation period for a declaratory judgment action begins when an actual controversy exists.

Konidaris v. Portnoff Law Associates., Ltd. · filed 2005-09-16(8)

Because an action for declaratory judgment cannot be sustained until these elements can be shown to exist, it follows that a cause of action for declaratory judgment does not arise until such “actual controversy” exists. Id. The four year “catch-all” statute of limitations begins to run at that time. Id.; see 42 Pa.C.S. § 5525(8).

Section 5525(a)(1) provides a four-year limitation period for a lease-breach claim.

Giant Eagle, Inc. v. Phar-Mor, Inc. · filed 2008-05-19(a)(1)

This is well within the four-year statute of limitations.

Section 5525’s four-year limitation period applies to Procurement Code payment claims seeking penalties and attorney’s fees as additional contractual damages.

Mastercraft Woodworking Co. v. Jim Lagana Plumbing & Heating Inc. · filed 2009-07-27

We also find that the penalty and attorney’s fees provisions of the Procurement Code do not provide a separate claim under tort, but allow additional damages on a contractual claim initiated under its provisions. Accordingly, the statute of limitations for a breach of contract, four years, under 42 Pa.C.S. §5525, applies to Counts V and X of the second amended complaint.

Section 5525(8) gives declaratory judgment actions a four-year limitation period, which the protected parties may waive by their conduct.

Cherry Timber Associates, Inc. v. Mitchell · filed 2010-02-10(8)

Declaratory judgments are subject to the four-year “catch all” statute of limitations. Wagner v. Apollo Gas Co., 582 A.2d 364 (Pa. Super. 1990) (citing 42 Pa.C.S.A. §5525(8)). ... In this action, the court finds that defendants waived the four-year statute of limitations by their conduct. The court finds that in the correspondences between the parties’ attorneys and the escrow agent, the parties agreed that the proceeds should remain in escrow until this matter was resolved.

Section 5525(8)’s four-year period for a written-contract claim begins when performance is due if the injured party does not elect to treat an earlier repudiation as a breach.

Simon Wrecking Co., Inc. v. AIU Ins. Co. · filed 2004-12-29(8)

But if the injured party instead .opts to await performance, the cause of action accrues, and the statute of limitation starts to run, from the time fixed for performance rather than from the earlier date of repudiation.

Section 5525(a) provides a four-year limitations period for breach-of-contract claims.

In re: MUSHROOM TRANSPORTATION COMPANY, INC. · filed 2004-08-24(a)

In short, the bankruptcy and district courts correctly held that various two-year statutes of limitations governed Counts II and III (breach of fiduciary duty), V (wrongful conversion) and VII (negligence) in each adversary proceeding, and that a four-year statute of limitations period governed Count VI (breach of contract).7 ... 42 Pa.C.S.A. § 5525(a) (breach of contract).

Section 5525(a) provides a four-year limitations period for breach of contract claims.

Burtch v. Ganz · filed 2004-08-24(a)

In short, the bankruptcy and district courts correctly held that various two-year statutes of limitations governed Counts II and III (breach of fiduciary duty), V (wrongful conversion) and VII (negligence) in each adversary proceeding, and that a four-year statute of limitations period governed Count VI (breach of contract). ... 42 Pa.C.S.A. § 5525(a) (breach of contract).

Section 5525 provides a four-year limitation period for contract-based claims.

Trujillo v. State Farm Mutual Automobile Insurance · filed 2001-12-06(8)

Unlike his bad faith claim, the plaintiff’s contract-based claims are governed by the four-year statute of limitations.

Section 5525’s four-year limitation period bars a claim on a guaranty that is not a sealed instrument when enforcement begins after the period expires.

Polkowski v. Huskie Portfolio, LLC (In Re Polkowski) · filed 2003-05-01

From this review, I find, as a matter of law, that the guaranty is not a sealed instrument, and therefore, the statute of limitations has expired under 42 Pa.C.S.A. § 5525.

Section 5525(8) applies a four-year limitation period to actions on written contracts, including contracts under seal, that are not bonds, notes, or similar instruments.

Township of Indiana v. Acquisitions & Mergers, Inc. · filed 2001-03-19(8)

Having earlier concluded that the Phase II and III Set Aside Agreements are not performance bonds but rather constitute contracts between Com-Serv and the Township, we conclude that the four-year limitation period set forth in § 5525(8) applies making the instant action untimely.

Section 5525 sets a four-year limitation period for breach of contract claims.

Fasig v. Security-Connecticut Life Ins. · filed 1999-03-08

The statute of limitations for causes of action sounding in contract breach is four years. 42 Pa.C.S. §5525. The plaintiff must exercise reasonable diligence. Romeo & Sons Inc. v. Yezbak & Son Inc., 539 Pa. 390, 394, 652 A.2d 830, 832 (1995). Since the court has concluded the plaintiff failed to exercise reasonable diligence, his cause of action for breach of contract cannot proceed.

Section 5525(8) applies a four-year limitation period to written contract claims involving real estate.

Pennsylvania Footwear Corp. v. Midlantic Bank, N.A. (In re Pennsylvania Footwear Corp.) · filed 1996-08-14(8)

The instant action, sounding in contract, is therefore clearly within the broad scope of § 5525(8).

Section 5525(8) generally gives claims on written contracts, including contracts concerning real property, a four-year limitation period.

Joshua Hill, Inc. v. Whitemarsh Township Authority (In Re Joshua Hill, Inc.) · filed 1996-07-11(8)

We therefore may safely conclude that claims arising from written contracts generally, including those concerning real property, are governed by the four-year limitation period of § 5525(8).

Section 5525’s four-year period for contract actions applies to a diversity petition to compel arbitration under a contractual arbitration clause.

Painewebber Incorporated Sheldon Chaiken Lee H. Lovejoy Anthony Presogna Kevin Collins v. Henry J. Faragalli, Jr. · filed 1995-08-04

Because this action is based on a contractual arbitration clause, Pennsylvania’s four-year statute of limitations for contract actions applies. 42 Pa.C.S. § 5525 (1994).

Section 5525(8) gives contract actions a four-year limit; for this insurance coverage claim, the period began when the underlying litigation settled, not when coverage was denied.

UTI Corp. v. Fireman's Fund Ins. Co. · filed 1995-03-28(8)

Defendants are correct that the applicable statute of limitations for contract actions *368 under Pennsylvania law is four years.[4] 42 Pa.C.S.A. § 5525(8). ... We hold that, with regard to the water authority claim, the instant cause of action accrued on July 2, 1992, and the instant action, commenced within five months of that date, was timely.

Section 5525(8) gives a claim based on a written contract a four-year limitations period.

Dodge v. Susquehanna University · filed 1992-06-02(8)

This case is governed by Pennsylvania law, and the statute of limitations on a claim based on a written contract is four years. 42 Pa.C.S.A. § 5525(8) (Supp.1991). Plaintiff is still within the four-year period.

Section 5525(8) imposes a four-year limitation period on an action founded on a written equipment lease.

Unisys Finance Corp. v. U S Vision, Inc. · filed 1993-08-24(8)

We have no difficulty in concluding that the equipment lease agreement executed by the parties on September 2, 1986 which forms the basis of Unisys’ claim against U.S. Vision is a “contract, obligation or liability founded upon a writing.” As such, the terms of § 5525(8) are applicable.

Section 5525(8)’s four-year catchall limitation period applies to a declaratory judgment action when no specific provision of Section 5525 applies.

Wagner v. Apollo Gas Co. · filed 1990-11-09(8)

Since we find no specific articles of Section 5525 applicable, we find the four year “catch all” statute of limitations appropriate in this instance. 42 Pa.C.S.A. § 5525(8).

Section 5525(8) gives four years to bring a claim for breach of a collective bargaining agreement.

Storch v. Miller · filed 1991-01-23(8)

Both parties also agree that the four year statute of limitations at 42 Pa.C.S. § 5525(8)2 applies to the officers’ claim for breach of the collective bargaining agreement. The trial court held that the claim for breach of the collective bargaining agreement was time-barred because the officers were transferred to night shift in January, 1984, but the action was not filed until October, 1988. We agree.

Section 5525(8)’s four-year period for actions on written insurance contracts does not extend a policy’s statutorily required twelve-month suit period.

Lyons v. Nationwide Insurance · filed 1989-12-28(8)

We do not read paragraph 11 of the policy to conform the twelve month limitation period to the four year limitation period set forth in 42 Pa.C.S.A. § 5525(8), because paragraph 9 is not in conflict with statutes of Pennsylvania, but rather is in complete conformity with them.

Section 5525 requires an action founded on a written contract, including a claim to a lease’s right of first refusal, to be commenced within four years.

Southeastern Pennsylvania Transportation Authority v. Frankford 5206 Bar, Inc. · filed 1991-02-27

Pursuant to Section 5525 of the Judicial Code, 42 Pa.C.S. § 5525, actions founded upon a written contract must be commenced within four years. Application of this section here leads to the conclusion that the Bar’s claim to its right of first refusal was time-barred at the latest in February or March of 1989. See paragraph 11 of the Bar’s petition for appointment of a board of view. A time-barred claim clearly cannot be resurrected in a subsequent petition so as to create a compensable property interest.

Section 5525 sets a four-year statute of limitations for contract claims governed by Pennsylvania law.

Deisenroth v. Numonics Corp. · filed 1998-02-27

The Pennsylvania statute of limitations for contract claims is four years. 42 Pa.Cons.Stat. § 5525. Accordingly, any claim of breach of the Termination Agreement is time-barred.

Section 5525 requires actions on contracts, obligations, or liabilities founded on a writing to be commenced within four years, and the court applied that period to bar the University's contract claims accrued in 1999.

University of Pittsburgh v. Townsend · filed 2008-09-09

Pennsylvania law further sets forth a two-year statute of limitations for tort claims and a four-year statute of limitations for contract claims: ... The following actions and proceedings must be commenced within four years: ... 8. An action upon a contract, obligation or liability founded upon a writing not specified in (7), under seal or otherwise, except an action subject to another limitation specified in this subchapter. ... 42 Pa. Cons.Stat. § 5525. ... The University’s causes of action accrued in 1999 and therefore were barred by the applicable statutes of limitations.

Section 5525(a) provides a four-year statute of limitations for Pennsylvania contract actions.

Bamgbose v. Delta-T Group, Inc. · filed 2009-07-06(a)

The statute of limitations for Pennsylvania contract actions is four years. 42 Pa. Cons.Stat. § 5525(a). ... The Court concludes that the plaintiffs denial of benefits claim is more analogous to a contract claim than to a claim under the WPCL. ... Accordingly, it will apply Pennsylvania’s four-year statute of limitations for contract actions.

Section 5525 imposes a four-year limitations period on breach-of-contract claims, but that period does not apply to legal-malpractice allegations that merely recast professional negligence without alleging breach of a contractual term.

Knopick v. Downey · filed 2013-08-05

In that decision, the court specifically acknowledged that “[a] plaintiff claiming breach of contract is subject to a four-year statute of limitations,” 42 Pa. Cons.Stat. § 5525, but clarified that “claims do not fall within the four-year [breach of] contract limitation period merely because a contract may have existed between the parties, or because a contract between a plaintiff and a professional obliged the professional to exercise reasonable care.” ... Accordingly, Plaintiffs claim was not subject to the four-year statute of limitations applicable to breach of contract actions.

Section 5525 sets a four-year limitations period for breach-of-contract claims.

Perelman v. Perelman · filed 2013-10-25

In Pennsylvania, a four-year limitations period governs a breach of contract claim, 42 Pa. Cons. Stat. § 5525, and a two-year period governs tort claims of professional negligence, fraudulent misrepresentation, fraudulent concealment, and fraud, 42 Pa. Cons. Stat. § 5524.

Section 5525(a)(1) requires contract actions to be commenced within four years, with the limitations period running from the time of breach.

Jordet v. Just Energy Solutions, Inc. · filed 2020-12-07(a)(1)

Under Pennsylvania law, an action upon a contract “must be commenced within four years,” 42 Pa. Cons. Stat. § 5525(a)(1). For an action for breach of contract, this limitations period begins to run from the time of breach, Baird v. Marley Co., 537 F. Supp. 156, 157 (E.D. Pa. 1982) (citing cases). With the filing of the Complaint here in April 6, 2018 (Docket No. 1, Compl.), breach of contract claims prior to April 6, 2014, are time barred.

Section 5525(a) gives breach-of-contract actions a four-year limitations period that begins when the contract is breached.

ENVIRONMENTAL CONSTRUCTION SERVICES, INC. v. MENTA · filed 2022-04-22(a)

The statute of limitations for breach of contract under Pennsylvania law is four years. 42 Pa. Cons. Stat. § 5525(a) (2004). “The statute of limitations begins to run at the time the cause of action accrues. Under Pennsylvania law, in an action for breach of contract, the action accrues when the contract is breached.” ... Accordingly, Defendants’ breach of contract claims that accrued prior to November 1, 2015, are time-barred.

Section 5525(a)(1) requires a Pennsylvania breach-of-contract claim to be brought within four years of the breach.

Ditech Holding Corporation · filed 2023-06-01(a)(1)

The limitations period for a breach of contract claim in Pennsylvania is four years. 42 Pa. Cons. Stat. § 5525(a)(1); Borel Builders, Inc. v. Burke, No. 1445, 2023 WL 371660, at *5 (Pa. Super. Ct. Jan. 24, 2023) (“A breach of contract claim must be brought within four years of the breach.”).

Section 5525(8) imposes a four-year statute of limitations on breach-of-contract actions.

ZHANG v. DORRANCE PUBLISHING CO. · filed 2025-02-12(8)

In Pennsylvania, the statute of limitations for a breach of contract action is four years. 42 Pa. Cons. Stat. § 5525(8). ... As to breach of contract claim, it is also-time barred. “In a contract case, a cause of action accrues when there is an existing right to sue forthwith on the breach of contract.” ... Based on this averment, the four-year statute of limitations ran in 2017 at the latest.

Section 5525(a)(8)'s four-year limitations period for an underinsured motorist claim begins when the insured settles with or obtains an award from the underinsured driver.

State Farm Mutl Auto v. Rosenthal · filed 2007-04-20(a)(8)

Accordingly, we hold that the four-year statute of limitations begins to run when the insured settles his claim with or obtains an award from the underinsured driver.

Section 5525(a)(8)'s four-year limitations period for an underinsured motorist claim begins when the insured settles the claim with or obtains an award from the underinsured driver.

State Farm Mutual Automobile Insurance Co. v. Rosenthal · filed 2007-04-20(a)(8)

Accordingly, we hold that the four-year statute of limitations begins to run when the insured settles his claim with or obtains an award from the underinsured driver.

Section 5525 sets a four-year limitations period for breach-of-contract actions, which the court applied as the borrowed limitations period for the ERISA claims.

Young v. Verizon's Bell Atlantic Cash Balance Plan · filed 2010-08-10

The parties agree that Pennsylvania’s four-year statute of limitations for breach of contract actions, 42 Pa. Cons. Stat. § 5525, should apply to this ERISA case. ... We further note that the Plan contains a choice of law provision stating that Pennsylvania law will fill any gaps left by federal ERISA law. ... None of the parties’ claims accrued before 2005 when Young brought her federal court ERISA action, so these claims are timely under the applicable Pennsylvania four-year limitations period.

Section 5525 provides Pennsylvania’s four-year limitations period for breach-of-contract actions and may be borrowed as the limitations period for an ERISA claim when Pennsylvania has the most significant connection to the dispute.

Young v. Verizon's Bell Atlantic Cash B · filed 2010-08-10

The parties agree that Pennsylvania’s four-year statute of limitations for breach of contract actions, 42 Pa. Cons. Stat. § 5525, should apply to this ERISA case. ... None of the parties’ claims accrued before 2005 when Young brought her federal court ERISA action, so these claims are timely under the applicable Pennsylvania four-year limitations period.

Section 5525 provides a four-year limitations period for breach-of-contract claims, which applies when Pennsylvania is the jurisdiction where the claim accrued.

Dynamics Inc. v. Samsung Electronics Co., Ltd. · filed 2024-04-05

Pennsylvania has a four-year statute of limitations for breach of contract claims. 42 Pa. Cons. Stat. § 5525 (2002). Because Pennsylvania’s four-year limitations period is shorter than New York’s six-year limitations period, see N.Y. C.P.L.R. § 213(2), Pennsylvania’s statute of limitations is applicable, see N.Y. C.P.L.R. § 202.

Section 5525 provides a four-year statute of limitations for breach-of-contract claims.

Wells Fargo Bank, N.A. v. AG · filed 2026-01-15

Kansas and Pennsylvania have, respectively, a five-year and four-year statute of limitations for breach of contract (Kan. Stat. Ann. § 60-511[1]; 42 Pa. Cons. Stat. § 5525). ... Accordingly, this breach of contract action, commenced in 2024, is time barred ( see CPLR 202; see also Deutsche Bank Natl. Trust Cp. V Barclays Bank PLC , 34 NY3d 327, 334 [2019]).

Section 5525 provides a four-year statute of limitations for actions involving express and implied contracts.

NEWLAND · filed 2026-05-12

Under that doctrine, “[i]f the local statute of limitations has not run, it is generally presumed defendant has not been prejudiced; if it has run, the converse is presumed.” Id. at 75. Here, the Pennsylvania statute of limitations applicable to express and implied contracts is four years. 42 Pa. Cons. Stat. § 5525. Even assuming that a cause of action based upon the warranty accrued as early as May 11, 2022, i.e., when the CTC Defendants’ rigging broke, the Court presumes that the less-than-four-year delay in raising this claim does not prejudice the CTC Defendants.

Section 5525(a)(8) provides a four-year limitations period for an action for breach of a written agreement.

Layne Christensen Co. v. Bro-Tech Corp. · filed 2011-12-23(a)(8)

Thus, Layne argues that Kansas would borrow Pennsylvania’s four-year statute of limitations for a claim for breach of a written agreement, 42 Pa. Cons.Stat. § 5525(a)(8). ... The Court agrees with Layne that the Pennsylvania four-year statute of limitations applies through the Kansas borrowing statute for purposes of determining whether the two claims coexisted here at any point in time.

Section 5525(a)(8) provides a four-year limitations period for actions upon a contract.

Muto v. CBS Corp. · filed 2012-02-01(a)(8)

Pennsylvania imposes a four-year limitations period for breach of contract actions. See 42 Pa. Cons. Stat. § 5525(a)(8). Because it is shorter than the analogous New York period, we apply the Pennsylvania statute and conclude, as did the district court, that the statute ran early in 2008 and thus bars plaintiffs’ suit, filed in 2009.

Section 5525(a)(8) imposes a four-year limitations period on actions based on written contracts.

Dille Family Trust v. Nowlan Family Trust · filed 2016-09-16(a)(8)

Pennsylvania’s four-year statute of limitations on written contract claims applies here.

Section 5525(8) requires an action on a written contract, obligation, or liability not otherwise covered by the subchapter to be commenced within four years.

Grabis v. Navient Solutions, LLC · filed 2020-12-11(8)

Similarly, the Debtor’s breach of contract claims are time barred under Pennsylvania’s four-year statute of limitations. See 42 Pa. Cons. Stat. § 5525(8).81 A complaint asserting a breach of contract claim must be filed within four years of “the time when a claimant first knows that the benefit has been infringed or removed,” or the statute of limitations will bar the claim.

Section 5525(8) imposes a four-year statute of limitations on breach-of-contract actions.

THE PR LIQUIDATING TRUST v. WESTERN LAND SERVICES, INC · filed 2021-03-30(8)

In Pennsylvania, the statute of limitations for a breach of contract action is four years. See 42 Pa. Cons. Stat. § 5525(8).

Section 5525 requires an action on an express contract not founded on a written instrument to be commenced within four years.

TRIVEDI v. CHANDAN · filed 2024-04-11

Under Pennsylvania law, “[t]he statute of limitations for a breach of contract claim is four years.” Steiner v. Markel, 968 A.2d 1253, 1255 n.5 (Pa. 2009); 42 Pa. Cons. Stat. § 5525 (“An action upon an express contract not founded upon an instrument in writing” must be “commenced within four years.”). ... Thus, Plaintiffs’ cause of action for any breach of the Reimbursement Agreement accrued, at the latest, on January 10, 2016, and the statute of limitations on any claim for breach of the Reimbursement Agreement expired on January 10, 2020.

Section 5525 gives contract actions a four-year limitations period.

U.S. Bank National Ass'n Ex Rel. Benefit of the Certificate Holders Under the Pooling & Servicing Agreement v. First Ame · filed 2014-06-20

The statute of limitations for contract actions is four years. 42 Pa. Cons. Stat. § 5525. Because U.S. Bank filed suit approximately five years after the sheriff’s sale, its contract claim was untimely.

Section 5525 gives four years to bring an action upon a contract.

Sköld v. Galderma Laboratories, L.P. · filed 2015-04-17

Pennsylvania’s statute of limitations to file contract actions is four years. 42 Pa. Cons.Stat. § 5525. ... Thus, taking the well-pleaded allegations in the Complaint as true, and drawing all reasonable inferences in Skold’s favor therefrom, the Court will not dismiss the contract claims on statute of limitations grounds, at least at this stage of the proceedings. Accordingly, the motions to dismiss the breach of contract claim in Count Five on this ground shall be denied.

Section 5525(a)(8) imposes a four-year limitations period on contract actions that begins when the contract breach occurs, including when disability benefits are clearly terminated.

Leporace v. New York Life and Annuity · filed 2015-08-10(a)(8)

Because it is clear that the payment of disability benefits ceased on May 31, 2005, the four year statute of limitations in § 5525(a)(8) for contract actions began to run at that time. Thus, any claim for benefits retroactive to May 31, 2005, expired on May 31, 2009. As a result, the complaint filed in March of 2011 was time-barred under § 5525(a)(8).

Subsection (a) provides a four-year statute of limitations for actions brought under a contract.

Balberdi v. Fedex Ground Package System, Inc. · filed 2016-06-29(a)

The arbitrator’s subsequent application of Pennsylvania’s four-year statute of limitations for breach of contract was equally reasonable under the FAA. See id.; see also 42 Pa. Cons. Stat. § 5525(a) (stating that the statute of limitations for an action brought under contract is four years). The Court FINDS that the arbitrator did not exceed her powers when she applied the relevant Pennsylvania statute of limitations.

Subsection 5525(8) gives express-contract and implied-in-law contract actions a four-year limitations period.

Haugh v. Allstate Insurance Company · filed 2003-02-28(8)

Rather, he may have a viable contract claim as Pennsylvania’s statute of limitations with respect to express contracts or contracts implied in law is four years. 42 Pa. Cons.Stat. § 5525.

Section 5525(8) gives breach-of-contract actions a four-year limitations period, which begins when the right to sue arises and is not postponed by contractual claim-filing provisions.

U.S. Bank, National Ass'n v. First American Title Insurance · filed 2013-05-08(8)

In Pennsylvania, the statute of limitations for a breach of contract action is four years. ... Although there exist contractual provisions in the title insurance policy that make the process of filing a claim less than clear, as discussed more thoroughly below, those provisions do not impact when the statute of limitations began to run. Accordingly, as this suit was instituted more than four years after the sheriffs sale, U.S. Bank’s breach of contract claim is time-barred.

Section 5525(a)(7) sets a four-year limitations period for breach-of-contract actions.

Norm's v. Atlas Noble · filed 2015-05-08(a)(7)

An action for breach of contract is subject to a four-year statute of limitations. 42 Pa.C.S.A. § 5525(a)(7).

Section 5525(a)(8) generally requires an action on a written contract to begin within four years, unless another limitation period applies.

Driscoll, R. v. Arena, J. · filed 2018-02-12(a)(8)

Given that the Complaints in Confession of Judgment were filed after both the four-year and six-year statute of limitations had expired, the Judgments in Confession were void, and the trial court properly entered the Orders striking the same.

Section 5525 sets a four-year limitations period for breach-of-contract claims; an amendment cannot save a claim filed after that period expired.

Feingold, A. v. State Farm Insurance Co. · filed 2019-05-17

Further, we find no abuse of discretion in the trial court declining to allow Feingold to amend his complaint. The trial court noted that the statute of limitations had long expired for both breach of contract, 42 Pa.C.S. § 5525 (four years), and bad faith, 42 Pa.C.S. § 5524 (two years). Here, Feingold filed his complaint more than 23 years after the Wallaces’ accident and 13 years after all of the Wallaces had turned at least 18 years old. Feingold’s brief does not show how a more specific amended complaint would overcome the statute of limitations.

Section 5525(a) governs the limitations period for breach of contract claims involving contracts other than sales of goods.

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

There are two statutes that establish a limitations period for claims based on breach of contract in Pennsylvania: one governing contracts for the sale of goods and the other governing all other contracts. See 13 Pa. C.S.A. § 2725; 42 Pa. C.S.A. § 5525(a).

Section 5525’s four-year limitation period does not apply when another statute provides a specific limitation period for the claim.

In Re: Appeal of J. Cox · filed 2019-12-16(a)(4)

Because the MCTLA provides a specific time, six years, it inherently overrides the limited scope of Section 5525. The four-year statute of limitations does not apply here.

Section 5525(a) sets a four-year limitations period for breach-of-contract claims.

Brown, K. v. Rite Aid Corporation · filed 2020-07-01(a)

The statute of limitations for a claim of breach of contract is four years. See 42 Pa.C.S.A. § 5525(a). ... Under the facts of this case, Brown’s lawsuit, filed 15 years after the payments ceased, is untimely.

Section 5525 gives an insured four years from the insurer’s denial of coverage to bring a breach of contract claim.

LM GENERAL INSURANCE COMPANY v. LEBRUN · filed 2020-07-01

Because a four-year statute of limitations applies, we hold that the face of the LeBruns’ complaint illustrates that the statute of limitations bars claims in which LM General denied coverage because of the household exclusion prior to June 17, 2015.

Section 5525(a)(1) sets a four-year limitations period for breach of contract claims.

TAGGART v. Deutsche Bank National Trust Company · filed 2021-06-03(a)(1)

Second, and more important, Deutsche Bank is correct—Pennsylvania’s four-year statute of limitations bars Taggart’s breach of contract claim based on alleged conduct from 2010.

Section 5525(a) sets a four-year limitations period for breach of contract claims.

PLOEGER v. TRUSTEES OF THE UNIVERSITY OF PENNSYLVANIA · filed 2023-01-31(a)

“Pennsylvania imposes a . . . four-year statute of limitations for breach of contract claims[.]” In re Olick, 829 F. App’x 586, 588 (3d Cir. 2020) (citing 42 Pa. C.S. § 5525(a)). ... Accordingly, because Count I’s breach of contract claim is untimely, it will be dismissed as time-barred.

Section 5525(7) supplies a four-year limitations period for an unsealed HELOC and mortgage.

MCDONOUGH v. LEOPOLD & ASSOCIATES, PLLC · filed 2024-07-16(7)

Because neither the HELOC nor the Mortgage is an instrument under seal, the twenty-year statute of limitations in 42 Pa. C.S. § 4429(b)(1) does not apply and the applicable statute of limitations is four years, pursuant to 42 Pa. C.S. § 5525(7).

Section 5525(a)(8) provides a four-year limitations period for contract claims.

Ettah, L. v. Contributionship · filed 2025-06-24(a)(8)

Generally, the statute of limitations period on a contract claim is four years. See 42 Pa.C.S.A. § 5525(a)(8). ... In sum, Ettah’s suit filed five years after the date of loss was barred by both the two-year limitations period in his insurance contract and the four-year statute of limitations applicable to contract claims.

Section 5525(8) gives contract claims a four-year limitation period that applies to a motion to enforce a settlement agreement.

Soltis v. CVS Pharmacy, Inc. · filed 2025-07-25(8)

Contract claims are subject to a four-year statute of limitations in Pennsylvania. 42 Pa. C.S.A. § 5525(8). ... Its motion seeking enforce the Term Sheet is time-barred under Pennsylvania law.

Section 5525(a)(1) requires breach of contract and warranty claims to be filed within four years after they accrue.

CONZEMIUS · filed 2026-06-10(a)(1)

“must be commenced within four years” of such claim accruing. 42 Pa. C.S.A. § 5525(a)(1).

Section 5525(8) imposes a four-year limit on written-contract actions unless another limitations provision applies; for real-estate-sale specific-performance or noncompliance claims, the court treated § 5526(2)'s five-year period as controlling.

Millay v. Marino · filed 2015-04-10(8)

The primary issue underlying these preliminary objections is whether the claims are governed by the four year statute of limitations that typically apply to written contract claims, under 42 Pa. Cons. Stat. § 5525(8)(“four year period”), or the five year statute of limitations “for specific performance of a contract for sale of real property or for damages for noncompliance therewith” under 42 Pa. Cons. Stat. § 5526(2)(“five year period”). The four year period applies to contract claims “except an action subject to another limitation specified[.]” ... This court is persuaded that the five year limitation period applies to claims for specific performance and similar noncompliance issues with respect to the sale of real estate even when title is not at issue. ... Therefore, the court believes the claim for specific performance and noncompliance thereto is governed by the five year limitation period.

Section 5525(8) imposes a four-year limitations period on breach-of-contract claims, and § 5525(4) imposes a four-year limitations period on unjust-enrichment claims.

RIAD v. WELLS FARGO BANK, N.A. · filed 2020-08-06(8), (4)

Pennsylvania law imposes a four-year statute of limitations on claims for breach of contract and unjust enrichment. 42 Pa. Cons. Stat. § 5525(8) (breach of contract); 42 Pa. Cons. Stat. § 5525(4) (unjust enrichment). ... As the statute of limitations for negligence, negligent hiring, and conversion is two years, the statute of limitations for breach of contract and unjust enrichment is four years, the statute of limitations for UTPCPL claims is six years, and as Plaintiffs’ cashier’s check claims accrued, at the latest, on December 31, 2012, and because Plaintiffs did not file the instant lawsuit until September 18, 2019, all causes of action based on the cashier’s check claims are untimely. See cases cited supra pp. 8-9. Defendant is entitled to judgment as a matter of law on Counts 1-6 relating to the cashier’s check claims. Therefore, the Court grants summary judgment as to Counts 1-6 relating to the cashier’s check claims in favor of Defendant.

Section 5525(a) imposes a four-year limitations period on breach-of-contract claims, and subsection (a)(4) imposes a four-year period on unjust-enrichment and quantum-meruit claims.

WILLIAMS v. ELLIOTT · filed 2024-08-26(a), (a)(4)

In Pennsylvania, the statute of limitations for a breach of contract action is four years, whether the contract is in writing or verbal, 42 Pa. Cons. Stat. § 5525(a), and “accrues at the time of breach.” ... The statute of limitations for unjust enrichment and quantum meruit claims is four years. 42 Pa. Cons. Stat. § 5525(a)(4). An unjust enrichment claim accrues “when the defendant receives and retains benefits,” ...

Section 5525 gives Pennsylvania breach-of-contract claims a four-year statute of limitations.

JALON v. BANK OF AMERICA · filed 2024-09-30

The statute of limitations for both federal RICO claims and Pennsylvania breach of contract claims is four years. LabMD Inc. v. Boback, 47 F.4th 164, 179 (3d Cir. 2022) (“The limitations period for a federal RICO claim is four years.”); 42 Pa. Cons. Stat. § 5525 (stating that the statute of limitations for breach of contract claim is four years).

Subsection (4) gives quasi-contractual unjust-enrichment claims a four-year statute of limitations.

STUFF ELECTRONICS (DONG GUAN) LIMITED v. FOR YOUR EASE ONLY, INC. · filed 2024-08-07(4)

A four-year statute of limitations applies to claims under the quasi-contractual theory of unjust enrichment.

Section 5525(8) sets a four-year limitations period for breach-of-contract claims.

Andrews, N. v. Cross Atlantic · filed 2015-09-09(8)

We note that the statute of limitations for a claim under the WPCL is three years, see 42 Pa.C.S.A. § 260.9a(g), and the statute of limitations for breach of contract is four years, see 42 Pa.C.S.A. § 5525(8).

Section 5525(a)(4) sets a four-year limitations period for unjust enrichment claims.

Miller, W. v. Miller, M. · filed 2015-11-04(a)(4)

The statute of limitations on an unjust enrichment claim is four years.

Section 5525(a) gives breach of contract claims a four-year limitations period.

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

Under Pennsylvania law, a four-year statute of limitations applies to breach of contract claims. 42 Pa. C.S. § 5525(a).

Section 5525 does not bar a warranty claim over separately purchased engine components when the claim is filed within four years of their purchase, even though the engines were sold earlier.

Lease Navajo, Inc. v. Cap Aviation, Inc. · filed 1991-04-03

The Court, therefore, having already determined that the focus is appropriately on the purchase of the component parts, and not the engines, finds that on the record now before the Court, the warranty claims are not barred by the statute of limitations.

Section 5525(3) provides a four-year limitation period for actions based on express contracts not in writing, which the court applied to the breach-of-warranty claim.

Orndorff v. Small · filed 1986-11-13(3)

As to the breach-of-warranty count the longest applicable statute of limitations would be the four year limitation to actions based on express contracts not in writing. Act of July 9, 1976, P.L. 586, §2, as amended, 42 Pa.C.S. §5525(3). This four year statute of limitations would have expired in July of 1985 since tender of delivery and the alleged representations were made in July of 1981.

Section 5525’s general contract limitation gives way to section 2725 in breach of warranty actions involving leases.

Cucchi v. Rollins Protective Services Co. · filed 1988-08-11

Section 2725, therefore, prevails over section 5525 in breach of warranty actions.

Section 5525(1) sets a four-year limitation period for assumpsit actions based on contracts for furnishing tangible personal property.

Hertz Commercial Leasing Corp. v. Nissenbaum · filed 1979-12-26(1)

The new Judicial Code, July 9, 1976, P.L. 586, effective June 27, 1978, reduced the statute of limitations from six years to four years for an assumpsit action based on a contract for the furnishing of tangible personal property: 42 Pa.C.S.A. §5525(1).

Section 5525(1) and (3) impose a four-year limitations period on claims arising from the sale of a painting, including a claim framed as rescission for mutual mistake.

Firestone & Parson v. Union League of Philadelphia · filed 1987-04-14(1), (3)

Irrespective of the applicability of the Uniform Commercial Code, the same result — application of a four-year limitations period — is mandated by 42 Pa.C.S.A. § 5525(1) and (3). Accordingly, I conclude that Pennsylvania law provides a four-year limitations period for cases of this kind.

Section 5525(8)’s four-year limitation period applies to claims for past-due payments under a postnuptial support agreement when the claimant seeks money owed under the agreement.

Horowitz v. Horowitz · filed 1991-12-18(8)

The hearing court determined the separation agreement constituted a written contract and, as such, a four year statute of limitations applied. 42 Pa.C.S. § 5525(8). ... The hearing court, however, concluded the only relief sought by wife was the payment of money due under the language of the agreement. We agree.

Section 5525(1)’s four-year limitation does not apply to an action for breach of a marital support agreement.

Hooker v. Hammer · filed 1980-06-27(1)

A marital support obligation, therefore, does not qualify as tangible personal property.

Section 5525(a)(8)’s four-year period does not govern a guaranty under seal that qualifies as an instrument subject to the twenty-year period in § 5529(b)(1).

Osprey Portfolio, LLC v. Izett · filed 2011-11-21(a)(8)

Under this definition, we determine that the Guaranty, which was undisputedly signed under seal, is, in fact, an “instrument” because it defines the rights, duties, entitlements, and liabilities of the parties involved, and therefore, the applicable statute of limitations is the twenty-year statute set forth in 42 Pa.C.S.A. § 5529(b)(1).

Section 5525(7)’s four-year limitation period does not apply to an action on a written instrument under seal; Section 5529(b)(1) supplies a 20-year period.

Joan Glisson Trust v. Delaware Valley Saving Bank · filed 2014-10-08(7)

In this regard, we reject Alliance Bank’s argument that the four-year statute of limitations set forth in 42 Pa.C.S. § 5525(7) is applicable, and bars the Trust’s contract claim.

Section 5525(a)(8)’s four-year period does not apply to assessment claims founded on deeds under seal when section 5529(b)(1)’s twenty-year period governs.

Meadow Run/Mountain Lake Park Ass'n v. Bantell · filed 2009-12-04(a)(8)

We conclude that the trial court correctly determined that section 5529(b)(1) applies to the Association’s claims. Section 5529(b)(1) states that, “Notwithstanding section 5525(7) (relating to four year limitation), an action upon an instrument in writing under seal must be commenced within 20 years.”

Section 5525(1) requires an action on a contract for the sale of tangible personal property to be brought within four years, even if the contract is under seal.

Industrial Valley Bank & Trust Co. v. Sharpe · filed 1980-08-27(1)

Plaintiff’s alternative argument that the MVISC at issue is a sealed instrument with no statute of limitations is without merit. The Code, 42 Pa.C.S.A. §5525(1), specifies: “An action upon a contract, under seal or otherwise, for the sale, construction or furnishing of tangible personal property or fixtures” must be commenced within four years.

Section 5525(8) gives an action for breach of a written contract not under seal a four-year limitation period.

Packer Society Hill Travel Agency, Inc. v. Presbyterian University of Pennsylvania Medical Center · filed 1993-12-28(8)

For all these reasons, therefore, we conclude that a cause of action for an alleged breach of the written contract in the instant case, which was not under seal, is subject to the four year statute of limitations at 42 Pa.C.S. § 5525(8).

Section 5525(7)'s four-year limitation period does not apply to a contract signed under seal.

Beneficial Consumer Discount v. Dailey · filed 1994-09-29(7)

If they did, Beneficial’s action to enforce the agreement was timely. If they did not, the action is barred by the statute of limitations. We find that they signed a contract under seal and affirm the trial court. ... The Daileys claim that they did not understand that they were signing a sealed agreement, and that the general four-year statute of limitation governing contracts, 42 Pa.C.S.A. § 5525(7), should apply. We disagree.

Section 5525(7) generally gives contract actions a four-year limitations period, but a contract under seal is subject to a 20-year period.

Action Management Inc. v. Gross · filed 2001-01-12(7)

On its face, this argument has appeal as contracts are generally subject to a four-year statute of *416limitations. 42 Pa.C.S. §5525(7). However, exhibit P-1 bears the word “seal” to the right of both defendants’ signatures. The effect of “seal” either preprinted or handwritten, adjacent to one’s signature has long been resolved. Lorah v. Nissley, 156 Pa. 329, 27 A. 242 (1893). The use of “seal” extends the statute of limitations to 20 years. 42 Pa.C.S. §5529(b)(l). Here, the “preprinted seal” creates a presumption that the defendants intended it as their “seal” extending the statute of limitations to 20 years. While I am certain few people understand this historic anomaly, it is still the law of the Commonwealth. As the defendants offered no evidence to rebut the presumption, plaintiff’s action is timely.

Section 5525 sets a four-year limit for actions on contracts for the sale of tangible personal property, whether or not the contract is under seal.

First National Bank v. Keefer · filed 2005-11-30(1)

We find that although the Judicial Code sets forth four years as the statute of limitations for contracts, irregardless of whether they are under seal or not, and because the transaction involves the sale of goods, that we must also be in conformity with Pennsylvania’s Commercial Code provisions.

Section 5525 provides a four-year limitations period for an action on a contract not under seal.

Kessock, J. v. Conestoga Title Insurance · filed 2018-08-09(a)

The statute of limitations for a contract not under seal is four years.

Section 5525(a)(8)’s four-year period does not apply to promissory notes that are sealed instruments subject to § 5529(b)(1)’s twenty-year period.

Driscoll, R. v. Arena, J. · filed 2019-06-17(a)(8)

In addition, we conclude that it was error for the trial court to grant Appellees’ petitions to strike the judgments based upon the applicable statute of limitations. The trial court found that the underlying promissory notes (the “Notes”) were not filed under seal and are therefore subject to the four-year statute of limitations of 42 Pa.C.S.A. § 5525(a)(8). ... In light of Loraw and the principles of contract interpretation referenced above, we conclude that the Notes are instruments under seal in accord with § 5529(b)(1).

Section 5525(a)(7) sets a four-year period for actions on written bonds, notes, and similar instruments, but an instrument under seal is subject to a twenty-year period.

Valley Natl. Bank v. Marchiano, P. · filed 2019-10-24(a)(7)

Section 5525(a)(7) of the Judicial Code provides a four-year statute of limitations for “[a]n action upon a negotiable or nonnegotiable bond, note, or other similar instrument in writing.” 42 Pa.C.S.A. § 5525(a)(7). However, section 5529 states, in relevant part, “[n]otwithstanding section 5525[a](7), . . . an action upon an instrument in writing under seal must be commenced within 20 years.” 42 Pa.C.S.A. § 5529(b)(1) (emphasis added). Thus, the proper limitation period hinges on whether the relevant documents were “under seal.” ... As the documents were under seal, a twenty-year statute of limitation applies.

Section 5525(a)(8) provides a four-year limit for actions on written contracts unless another limitation applies; a promissory note that takes effect as a sealed instrument is subject to the 20-year limit instead.

Wiley, C. v. Brooks, J. · filed 2021-09-24(a)(8)

Section 5525(a)(8) of the Judicial Code establishes a four-year statute of limitations period for, ... [a]n action upon a contract, obligation or liability founded upon a writing not specified in paragraph [(a)](7), under seal or otherwise, except an action subject to another limitation specified in this subchapter. ... Given Driscoll’s focus on the intent of the parties and observation that sealing has become constructive, we likewise conclude in this case that the promissory note evidences the intent to create an instrument under seal.

Section 5525(a)(3) sets a four-year limitation period for a breach of contract claim based on an oral agreement.

In Re: Est. of D. Zabresky Appeal of: M. Zabresky · filed 2015-04-30(a)(3)

Here, the trial court properly determined that Appellant’s breach of contract claim is governed by a four-year statute of limitations. See 42 Pa.C.S. § 5525(a)(3).

Section 5525(3) sets a four-year limitation period for actions on express contracts not founded on a written instrument.

Gunn Estate · filed 1993-04-20(3)

The court determines that this claim was subject to a four-year limitation under *61542 Pa.C.S. §5525(3) (“an action upon an express contract not founded upon an instrument in writing”) and was timely presented.

Section 5525(3) provides a four-year limitations period for oral contract actions.

Sanders v. State Farm Mutual Automobile Insurance · filed 1993-03-26(3)

Thus, the action was filed within the statutory limitations period for oral contract actions.

Section 5525(3) applies a four-year limitation period to oral-contract claims when no writing is alleged.

Geitz v. Borough of Chalfont · filed 1984-05-04(3)

The four year statute of limitations for oral contracts (no writing was alleged or attached to the complaint) applied to the claims raised by plaintiff against Phinney.

Section 5525 requires actions on contracts, whether express or implied in law, to be commenced within four years.

Dysart v. Marriott Corp. · filed 1984-06-15

Plaintiff’s other claims sound in breach of contract 42 Pa.C.S.A. § 5525 which provides that actions on a contract, whether express or implied in law, must be commenced within four years.

Section 5525(3) gives four years to bring an action on an express contract not founded on a written instrument, without the exception found in section 5525(4).

Monaghan v. Provident National Bank · filed 1985-09-27(3)

Therefore the applicable statute of limitations here is not section 5525(4), but section 5525(3), which provides a four-year limitation for “An action upon an express contract not founded upon a instrument in writing.” 42 Pa.C.S. § 5525(3). Unlike section 5525(4), section 5525(3) contains no exception, so the four-year limitation clearly applies here.

Section 5525 applies a four-year limitations period to claims for breach of an oral contract.

Culbreth v. Simone · filed 1981-01-15

If any contract existed, it was oral. As to these Counts, the court finds that the applicable statute of limitations, four (4) years, 42 Pa.C.S.A. § 5525 (Supp.1980), expired prior to commencement of the action.

Section 5525 gives a plaintiff four years to file an action for breach of an oral contract.

Bailey v. Tucker · filed 1993-02-26

Therefore, the longest possible period of limitations would be the four year period for an oral contract. See 42 Pa.C.S. § 5525. The instant action was filed beyond such four year period.

Section 5525 provides a four-year limitation period for breach of an oral contract.

Thousand Dollar Club v. Krispinsky · filed 2000-07-13

The breach of contract claim alleges the breach of an oral contract and is covered by a four-year limitation period. 42 Pa.C.S. §5525 (Supp. 2000); Packer Society Hill Travel Agency Inc. v. Presbyterian University of Pennsylvania Medical Center, 430 Pa. Super. 625, 635 A.2d 649 (1993).

Section 5525 provides a four-year limitations period for an assumpsit action based on an oral contract.

Harner v. McCormick · filed 1993-06-29

Then the applicable period for trespass is two years, 42 Pa. C.S. §5524; assumpsit for oral contract is four years, 42 Pa.C.S. §5525; and assumpsit for written contract is six years, 42 Pa.C.S. *377§5527.

Section 5525(3)'s four-year period does not apply to a § 1983 claim based on alleged defamation and termination of employment; the applicable period is two years.

Mazur v. Department of Revenue, Com. of Pa. · filed 1981-08-25(3)

Plaintiff counters, arguing that either the four year statute of limitations, provided for in 42 Pa.C.S.A. § 5525(3), or the six year statute of limitations, provided for in 42 Pa.C.S.A. § 5527(6) should apply. For the reasons set forth below, the court holds that the two year statute of limitations applies in this case.

Section 5525’s four-year limitation period does not govern a federal civil rights claim alleging discriminatory denial of tenure.

Al-Khazraji v. Saint Francis College · filed 1981-09-30

The sole question that remains is whether the applicable statute of limitations is the 4-year period contained in 42 Pa.C.S.A. § 5525, or the 6-year period contained in 42 Pa.C.S.A. § 5526. ... In either case, the 6-year limitation period is applicable.

Section 5525(a)(8)’s four-year period bars enforcement of an equitable distribution agreement that fixes payment when stock is sold if the claim is filed more than four years after payment becomes due.

K.A.R. v. T.G.L. · filed 2014-12-23(a)(8)

We agree with the trial court’s analysis. The “if and when” language of the agreement provided that the date that Husband sold the Business-1 stock — here, January 22, 2004 — was the specific date when Husband became obligated to make payment to Wife for the Business-1 sale. Moreover, the parties’ agreement identifies the amount owed to Wife, in terms of percentages of net proceeds received by Husband. Accordingly, we conclude Wife’s first argument presents no basis to disturb the trial court’s determination that the parties’ agreement is not a continuing contract and that the statute of limitations bars the present action.

Section 5525(a)(8)’s four-year limitation period does not begin to run while payment obligations under a continuing postnuptial agreement remain ongoing.

Miller v. Miller · filed 2009-10-09(a)(8)

Here, however, Husband continued to owe payments on the marital residence, an obligation that he had expressly assumed under sub-section 3.1 of the Agreement. Accordingly, the statute of limitations had not begun to run on Husband’s continuing payment obligations.

Section 5525’s four-year period bars a contract claim when the plaintiff knew the contractor’s work had failed more than four years before filing suit.

Gallagher v. Upper Darby Township · filed 1988-03-17

The trial court held that whether the two-year or four-year statute of limitations applied, see 42 Pa. C. S. §5524 and 42 Pa. C. S. §5525, Appellants action was clearly barred. ... In the instant case, it is quite apparent that Appellant knew that General Sewer had not solved her problem as evidenced by her employment of other plumbers to remedy the situation, and particularly her deposition testimony that Snyder was contracted in 1978 to do the same work which General Sewer had previously done, because the sewer problem worsened. ... We will affirm the trial courts entry of judgment in favor of General Sewer and against Appellant because those causes of action are time-barred.

A factual dispute over whether an oral agreement is a continuing contract can preclude summary judgment under Section 5525(3)’s four-year limitation period.

Wm. B. Tenny, Etc. v. Dauphin Deposit Bk. · filed 1982-07-02(3)

Thus, if appellant’s version of the facts is correct, the parties have a contract for financial advice, which because of its silence as to duration, is deemed to be continuous. ... Because there is a factual dispute as to the very essence of the underlying contract, and that issue is material to the determination of the statute of limitations question, we must reverse the lower court and remand for further proceedings on count one of appellant’s complaint.

Section 5525(3)’s four-year period for an oral contract does not depend on a demand for repayment when the agreement makes repayment contingent on neither a demand nor another condition.

Gurenlian v. Gurenlian · filed 1991-07-25(3)

Having carefully reviewed the record, we conclude that the agreement in the instant case was not one where a demand was necessary to perfect a cause of action, and, thus, the running of the statute of limitations was not contingent on a demand being made.

The four-year limitations period does not bar enforcement of a continuing property settlement agreement with ongoing obligations.

Crispo v. Crispo · filed 2006-09-27

In light of the foregoing authority, then, we find that the property settlement agreement is a continuing contract, and Appellant’s statute of limitations defense is inapplicable.

Section 5525(a) sets a four-year limit for contract suits; for a continuing contract, the period does not begin until the contractual relationship ends.

GAI Consultants, Inc. v. Homestead Borough · filed 2014-07-23(a)

Pennsylvania has a statute of limitations that requires lawsuits upon a contract to be commenced within four years. 42 Pa.C.S.§5525(a). ... I rejected Homestead Borough’s argument because I found the TIF Agreement is a “continuing” contract, which means the statute of limitations does not begin to run until termination of the contractual relationship.

The four-year limitations period for a continuing contract with no definite time for payment begins when the contractual relationship ends.

GAI Consultants, Inc. v. Homestead Borough · filed 2015-07-08(a)

Because the TIF Agreement sets no specific time for reimbursement claims for property tax refunds, it is a continuing contract. Accordingly, the statute of limitations would not begin running until the termination of the contract relationship in 2018 and does not bar the reimbursement claims of the School District, Allegheny County or Munhall for pre-2010 property tax assessment appeal refunds.

Section 5525(a)(8)’s four-year limitation period does not bar a claim to enforce a continuing contract when the payment obligation has not yet arisen.

Poli, A. v. Poli, L. · filed 2016-11-17(a)(8)

Accordingly, as the duties of Husband were ongoing, the contract was properly classified as “continuing” and the statute of limitations did not bar Wife’s claim.

Section 5525(a)(8) gives each recurring failure to pay rent its own four-year limitations period, barring claims that accrued more than four years before suit.

Tsung Tsin Associates v. Leun Fong Produce · filed 2019-04-09(a)(8)

Where, as here, a tenant has allegedly breached a series of reoccurring obligations to pay rent over the life of a lease, the statute of limitations, practically speaking, creates a “four-year-look-back” period. In short, 42 Pa.C.S.A. § 5525(a)(8) time-barred all causes of action arising prior to June 6, 2011, while any causes of action, accruing from a breach on or after that date, remained legally viable.

Section 5525(a)(8) gives a party four years to bring a contract claim; for a continuing contract, the period runs from breach or termination.

Weber, B. v. Weber, M. v. Weber, M. · filed 2019-04-26(a)(8)

As discussed above, any breach of Paragraph 18 would have occurred, at the latest, “in 2011 when [Son] completed his studies at FSU,” see Memorandum & Order, 7/5/18, at 9, and the four-year statute of limitations began to run at that time.

Section 5525(a)(8) imposes a four-year limit on claims for unpaid rent under a lease; each missed payment gives rise to a separate claim.

WASHINGTON INVESTMENTS, LLC v. BLENDED, LLC · filed 2025-09-15(a)(8)

Given these circumstances, 42 Pa. C. S. § 5525(a)(8) time-bars the recovery for breaches that gave rise to a right to recovery prior to December 26, 2020, while recovery for any breaches occurring on or after that date remained legally viable.

Section 5525(a)(4) imposes a four-year limitations period on claims for quantum meruit and unjust enrichment.

Ecore Int'l, Inc. v. Downey · filed 2018-10-12(a)(4)

Even if Downey's quantum meruit claim were cognizable, it would nevertheless be barred because Downey did not assert it within Pennsylvania's four-year statute of limitations for contracts. See 42 Pa. C.S.A. §§ 5525(a)(4) (providing 4-year statute of limitation for an action upon a contract implied in law); Sevast v. Kakouras , 591 Pa. 44, 915 A.2d 1147, 1153 (2007) (stating that four-year statute of limitation applies to unjust enrichment claim).

Section 5525 gives unjust enrichment claims a four-year limitations period; an expired claim may still be asserted as a defense through equitable recoupment.

Poskin v. TD Banknorth, N.A. · filed 2009-09-11

Under Pennsylvania law, a claim for unjust enrichment has a four-year limitations period. 42 Pa. Cons.Stat. § 5525; ... Here, the four-year limitations period had expired by the time the claim was filed. Kenneth Poskin stopped paying on his loan in 2002 or 2003 at the latest, and defendant did not file the unjust enrichment claim until March 10, 2008. Nonetheless, defendant should be able to assert equitable recoupment at least as a defense to plaintiffs’ claims against it. Therefore, plaintiffs’ reliance on the statute of limitations does not defeat the defendant’s motion for summary judgment.

Section 5525(a)(4) gives quantum meruit claims a four-year limitations period; the continuing-contract exception does not apply to those claims.

Holmes v. Smith · filed 2004-04-16(a)(4)

Although Pennsylvania law recognizes an alternative date from which the statute of limitations runs when a continuing contract is involved, this exception applies only to a plaintiff’s contract cause of action (which Holmes is not appealing) and not to an action based on quantum meruit.

Section 5525(a)(4) gives a claimant four years to bring a quantum meruit claim based on a contract implied in law; when the claimant files a notice of claim before the estate account, the court measures the four years back from that notice.

Estate of Rubenstein · filed 2014-11-24(a)(4)

There is presently a specific statute of limitations in effect for a quantum meruit claim set forth in 42 Pa.C.S.A. §552527 as four years. ... Instead, she filed a notice of claim on August 24,2012 so that the statute of limitations should count back 4 years from that formal claim to August 24,2008.

Section 5525(a)(4) gives a defaulting buyer four years to bring an unjust enrichment claim, beginning when the sale contract is terminated rather than when the property is resold.

Sevast v. Kakouras · filed 2007-02-20(a)(4)

The cause of action which Appellee brought before the court is based upon a theory of unjust enrichment.7 According to statute, there is a four-year statute of limitations for such causes of action. ... Accordingly, James’, or Appellee’s, right to restitution based on a theory of unjust enrichment ripened the day the Court of Common Pleas for Lancaster County terminated the Long-Term Agreement of Sale. The statute of limitations for a cause of action against Appellants thus expired on January 29, 2001.

Section 5525(a)(4) provides a four-year limitation period for breach of implied contract claims; such a claim can proceed independently of a conversion claim.

Borough of Shippensburg v. Kelley · filed 2006-09-15(a)(4)

While acknowledging the statute of limitations for breach of implied contract is four years under 42 Pa.C.S. §5525(a)(4), they maintain the complaint sounds primarily in conversion which has only a two-year statute of limitations. ... Second, breach of implied contract is an independent cause of action with *220different elements of proof and different measures of damages than conversion and is based specifically on the Johnsons’ assertion in their defense that they were performing services under an oral contract with the borough. ... Based on the foregoing, the borough is not barred as a matter of law from pursuing the breach of implied contract claim.

Section 5525(4) gives a discharged attorney four years from termination of representation to bring a quantum meruit claim and bars an amendment adding that claim after the period expires.

Cherry v. Zucker · filed 2002-01-18(4)

The statute of limitations for a quantum meruit action is four years from the date of termination of the attorney’s representation, and amendment of a pleading to add such an action will not be permitted after the four years limitations period has run.

Section 5525(4) gives a discharged attorney four years from termination to bring a quantum meruit claim against a former client.

Kenis v. Perini Corp. · filed 1996-09-18(4)

Boyce’s claim against plaintiffs accrued as of the date of her termination — April 18, 1995. She has four years from April 18, 1995, or, until April 18, 1999, within which to bring her action against plaintiffs. 42 Pa.C.S.A. § 5525(4).

Section 5525(4)’s four-year limitations period does not govern an equitable unjust enrichment claim; delay is assessed under laches.

Sim Kar Lighting Fixture Co. v. Genlyte, Inc. · filed 1995-11-08(4)

Sim Ear argues that Moushegian’s unjust enrichment claim is time barred under the four year statute of limitations for indemnity actions under Pennsylvania law. 42 Pa.C.S.A. § 5525(4). ... To this Court, the Bridge-stone route is appropriate; Sim Ear’s argument will be analyzed as a laches defense.

Section 5525(4) gives a four-year limitation period for quantum meruit claims based on contracts implied in law.

Bednar v. Marino · filed 1994-08-15(4)

The four year period of limitations applicable to contracts implied-in-law governs an action based upon a theory of quantum meruit.

Section 5525(4) gives a quantum meruit action a four-year limitation period.

Fowkes v. Shoemaker · filed 1995-06-07(4)

The statute of limitations for a quantum meruit action is four years. ... A quantum meruit action against the Zeiglers would have been time-barred by the statute of limitations. The Zeiglers terminated appellants in December, 1988, and appellants commenced this action approximately four and one-half years later, on June 30, 1993.

Section 5525(4) imposes a four-year limitation on actions based on implied-in-law contracts, including quantum meruit claims.

Ragnar Benson, Inc. v. Bethel Mart Associates · filed 1982-12-23(4)

An action upon an implied-in-law contract is subject to a four year limitation, 42 Pa.C.S.A. § 5525(4).

Section 5525(4) gives a claimant four years to sue an assigned servicing insurer for uninsured motorist benefits because the insurer’s obligation is a contract implied in law; the claim accrues when the insurer is assigned.

Rotz v. Insurance Co. of North America · filed 1984-06-08(4)

Section 5525 of the Act of July 9, 1976, P.L. 586, §2, 42 Pa. C.S. §5525 provides inter alia: “The following actions and proceedings must be commenced within four years: (4) An action upon a contract implied in law. . .” Therefore, we conclude the statute of limitations applicable herein is four years. ... As against INA his rights did not vest until his claim was assigned.

Section 5525(4)’s four-year period for contracts implied in law does not apply when the pleaded claim is for taking or detaining another’s money.

American Insurance Co. v. Ford Motor Credit Co. · filed 1994-10-04(4)

The allegations of “taking” or “detaining” money to which it had no right, cause the claim made in Appellant’s Complaint to fall under the two year limitation period contained in § 5524(3). Appellant argues that prior case law requires us to consider this case as a suit for “money had and received.” As such Appellant reasons that the four year limitation period of 42 Pa.S.C.A § 5525(4) would apply for action upon a contract implied in law. ... Finding no contrary precedent, we conclude that the trial court did not error in applying the two year limitation period of § 5524(3), in this action.

Section 5525(a)(4) gives a claimant four years to bring an unjust enrichment claim after the right to sue arises, unless the limitation period is tolled.

Ross, B. v. Estate of Roberts, H. · filed 2023-09-15(a)(4)

Plaintiff’s right to institute suit for unjust enrichment therefore arose when Decedent received Plaintiff’s services without compensating Plaintiff and her claims for services that she provided to Decedent more than four years before she brought this action are barred unless Plaintiff has shown a basis on which her right to sue did not arise at that time or the statute of limitations was tolled.

Section 5525(a)(4) sets a four-year limitation period for actions upon contracts implied in law, including quantum meruit claims.

NEPA Waterproofing v. Ruddy, B. · filed 2026-04-29(a)(4)

Section 5525(a)(4) establishes a four-year statute of limitations for actions upon contracts implied in law, including claims for quantum meruit.

Section 5525(a)(4) sets a four-year limitations period for unjust enrichment actions.

ALLEN · filed 2026-03-27(a)(4)

In Pennsylvania, an action for unjust enrichment has a statute of limitations of four years.

Section 5525’s four-year limitations defense is subject to repair estoppel when a seller or its agent expressly represents within four years of purchase that repairs will cure a product defect; repair attempts alone are insufficient.

Laurita v. International Harvester & Rish Equipment Co. · filed 1983-03-11

The decision on the motion before the court centers upon consideration of the relevant four-year statute of limitations. See 42 Pa.C.S. §5525; 13 Pa.C.S. §2725. ... We now decide to recognize the doctrine, holding that proof of defendants’ express representations that repairs to the machine in question would cure the defects is sufficient to provide plaintiff with an exception to the four-year statute of limitations period. We point out that mere attempts to repair are not sufficient. There must be representations made by defendant as to the curing effect of the repairs.

Section 5525(4) imposes a four-year limitation period on a discharged attorney’s claim for compensation.

Mager v. Bultena · filed 2002-03-26(4)

Since there is a four-year statute of limitations on such a claim, a discharged attorney who waited until the client obtained a verdict before asserting his claim, could find his right to any compensation barred by the expiration of the statute. See: Elliott Reihner Siedzikowski & Egan, P.C. v. Pa. Employees Benefit Trust Fund, 161 F.Supp.2d 413 (E.D.Pa.2001); 42 Pa.C.S. § 5525(4).

Section 5525’s four-year limitation period can apply to a legal malpractice claim that states a cause of action in contract.

D'Ambro v. Stradley, Ronon, Stevens & Young · filed 1996-02-08

As to plaintiff’s contract claim against the defendant, viewing the record in a light most favorable to the plaintiff, I find that the plaintiff has stated a cause of action against the defendant in contract.1 ... Defendant’s motion for summary judgment as to plaintiff’s contract claim is denied. ... I distinguish the case of Garcia v. Community Legal Services Corp., 362 Pa. Super. 484, 524 A.2d 980 (1987), on its facts. There, a four-year statute of limitations did not apply to a legal malpractice case where the complaintread “complaint in trespass” and the plaintiff did not include a contract count against the defendant.

Section 5525’s four-year limitation period governs a distinct breach of contract claim arising from professional treatment.

Tuman v. Genesis Associates · filed 1996-04-25

I therefore find that the four-year statute of limitations governs Plaintiffs’ breach of contract claim.

Section 5525(3)’s four-year period applies to a legal malpractice claim based on breach of contract only when the plaintiff establishes breach of a specific contractual term or instruction.

Costello v. Primavera · filed 1998-04-30(3)

Defendants argue that plaintiffs may not claim the four-year statute of limitations for breach of contract, 42 Pa.C.S. §5525(3), because they have failed to establish the requisite breach of a specific contractual term or instruction.57 This court agrees.

Section 5525(3)’s four-year period for non-written contracts does not govern a legal malpractice claim grounded solely in tort.

Pettit v. Smith · filed 1999-11-17(3)

To sustain a claim of legal malpractice that arises from a breach of contract, a plaintiff must show that there was a contract and that the defendant breached a specific provision thereof. ... We therefore must agree with Judge Twardowski that Mrs. Pettit’s legal malpractice claim is grounded solely in tort — not in contract.

Section 5525(3) and (4) provide a four-year limitation period for the contract claims at issue, which expired before the plaintiff filed suit.

Trice v. Mozenter · filed 1986-09-11(3), (4)

Thus, it matters not which one of the statutes of limitations we use to gauge the timeliness of the plaintiff’s suit, be it the two-year (42 Pa.C.S. § 5524(2)) or four-year (42 Pa.C.S. § 5525(3) and (4)) law, the fact remains that the complaint was filed beyond the strictures of the applicable statutes ... when presented to the prothonotary of Philadelphia County in August of 1984.

Section 5525’s four-year period for oral or implied contracts does not apply to a malpractice claim against court-appointed counsel when no attorney-client employment contract existed.

Moore v. McComsey · filed 1983-05-06(3) and (4)

If the action is based on an alleged breach of an oral contract of hiring or a contract implied in law, the limitation is four years. 42 Pa.C.S. § 5525(3) and (4). ... In the instant case, however, there was no contract of employment between appellant and trial counsel, for counsel had been court appointed. Similarly, we deem it unrealistic to attempt to confer upon appellant the status of a third party beneficiary to a contract between the Commonwealth and appointed counsel. We conclude, rather, that appellant’s cause of action was based not upon breach of contract by his counsel but upon *270the alleged negligence of counsel in handling his criminal case.

Section 5525 provides a four-year limitations period for legal malpractice claims based in contract.

Mahonski, J. v. Engel, C. · filed 2016-08-08

A four-year statute of limitations applies to the legal ... malpractice claim based in contract principles.

Section 5525(a) gives a plaintiff four years to bring a breach of contract claim against an attorney; the claim is barred if filed more than four years after the client knew or should have known of the alleged breach and injury.

Calkins, M. v. Butz, E. · filed 2017-01-23(a)

When Appellant filed a praecipe for a writ of summons on March 16, 2015, the breach of contract claim was barred by the four-year statute of limitations.

Section 5525(a)(8)’s four-year period applies to breach of contract actions, but not to a legal malpractice claim that sounds in tort because it alleges negligent performance rather than breach of a specific contractual promise.

Seidner, M. v. Finkelman, H. · filed 2018-08-31(a)(8)

Section 5525 of the Judicial Code sets forth a four-year statute of limitations for breach of contract actions. See 42 Pa.C.S.A. § 5525(a)(8). ... Hence, the trial court properly found that, pursuant to the “gist of the action” doctrine, Appellant’s claim sounded in tort and that, therefore, it violated the two-year statute of limitations.

Section 5525(a)(8) gives four years to file a criminal legal malpractice claim brought on a contract theory.

Schade, K. v. Lauer, P. · filed 2020-09-23(a)(8)

Because 42 Pa.C.S. § 5525(a)(8) required that action had to be filed within four years, the statute of limitations would have expired on January 7, 2019 (four years after sentencing) or, at the very latest, in June 2019, four years after Lauer filed a Petition to Withdraw, new counsel filed his Entry of Appearance, and the court dismissed the Petition to Withdraw as moot.