42 Pa. Cons. Stat. § 5525

Section 5525(1) applies a four-year limitation period to construction contract claims involving defective workmanship and building materials.

Luden's, Inc. v. Irwin & Leighton, Inc. · filed 1983-07-12(1)

This court holds that §5525(1) applies to the present construction contract case, as specifically stated in Crisante v. J. H. Beers, Inc., 297 Pa. Super. 337, 341 n. 5, 443 A.2d 1150, 1152 n.5 (1982).

Section 5525(8) gives claims on written contracts for the construction of real estate a four-year limitation period unless another period in the subchapter applies.

Gustine Uniontown Associates Ltd. v. Anthony Crane Rental Inc. · filed 2000-07-18(8)

The language of section 5525(8) could not be clearer: a single limitation period of four years governs actions upon any written contracts unless there is another limitation period specified in the subchapter.

Section 5525(a)(8) gives actions on written contracts, including real estate construction contracts, a four-year limitation period unless another period explicitly applies.

Gustine Uniontown Associates, Ltd. v. Anthony Crane Rental, Inc. · filed 2004-02-17(a)(8)

For the foregoing reasons, we hold that, except in circumstances where another limitations period explicitly applies, an action upon a written contract, including a contract for the construction of real estate such as is at issue here, is subject to the four-year period of limitations explicitly provided under Section 5525(a)(8).

Section 5525 does not make a sales-related indemnity claim subject to the UCC’s tender-of-delivery accrual rule merely by referring to actions governed by the UCC limitations provision.

Titanium Metals Corp. v. Elkem Management, Inc. · filed 1998-09-30(2), (4)

First, § 5525(2)’s reference to “[a]ny action subject to 13 Pa.C.S. § 2725” does not prove that indemnity actions related to the sales of goods are subject to § 2725; it simply begs the question. So, for that matter, does the language of § 5525(4), which excepts “actions subject to another limitations period.... ” Second, the mere fact that an action otherwise subject to § 2725 is to have a four-year limitations period (which § 2725 provides explicitly in any event) does not evidence a legislative intent specifically to incorporate the tender of delivery rule as well.

Section 5525(4) applies a four-year limitation period to indemnity claims because they are contractual in nature.

Snavely Silo Sales, Inc. v. Rockwood · filed 1983-09-13(4)

On June 27, 1978, Section 5525 of the Judicial Code, 42 Pa. C.S.A. §5525, became effective and provided that actions upon a contract implied in law were subject to a four year limitation period. 42 Pa. C.S.A. §5525(4). Due to its contractual nature, a claim for indemnity is governed by the Statute of Limitations applicable to contract actions.

Section 5525(4) does not govern an uninsured motorist benefits claim under the No-fault Act when no-fault benefits have already been paid.

Bragg v. State Automobile Insurance · filed 1986-01-24(4)

Appellee asserts that the applicable statute of limitations in the instant case is four years, as found in 42 Pa.C.S. § 5525(4). Appellants contest neither the length of the statute nor which is. applicable, but only the beginning date of the statute. We, however, cannot agree with the parties that the implied contract-in-law statute above even applies herein. Rather, this case seems to be controlled by our decision in Holland v. General Accident, Fire and Life Assurance Corp., Ltd., 339 Pa.Super. 433, 489 A.2d 238 (1985).

Section 5525(4) gives four years to bring an uninsured motorist benefits claim under the Assigned Claims Plan because the claim is based on a contract implied in law.

Walker v. Insurance Co. of North America · filed 1983-10-12(4)

Accordingly, plaintiff’s claim in the instant matter is governed by 42 Pa.C.S. §5525(4), the statute of limitation governing implied-in-law contracts. ... 42 Pa.C.S. §5525(4) provides that an action based upon a contract implied-in-law must be commenced within four years.

An extra-judicial arbitration demand does not commence or toll the four-year limitation period for an uninsured motorist benefits claim.

Erie Insurance Exchange v. Bristol, M. · filed 2016-05-27(a)

First, under the precedent established in Hopkins, Appellant’s extra-judicial demand for arbitration did not commence his action and it did not toll the four-year statute of limitations.

Section 5525(2)'s four-year limitation period does not bar a contract claim by the Commonwealth because the section does not expressly cover it.

Pennsylvania v. Lake Asphalt & Petroleum Co. · filed 1985-06-05(2)

Additionally, defendants raise the four year statute of limitations found in the Uniform Commercial Code, 13 Pa.C.S. § 2725, and at 42 Pa.C.S. § 5525(2). Plaintiff correctly points out, however, that a statute of limitations does not apply to the Commonwealth unless the Commonwealth is specifically covered by the statute. ... These statutory sections do not refer to the Commonwealth. Accordingly they do not bar the contract claim.

Section 5525(a)(8)’s four-year limit does not bar an intermediate unit’s claim to enforce a contract required by its statutory duties when nullum tempus applies.

Allegheny Intermediate Unit v. East Allegheny School District · filed 2019-01-25(a)(8)

Stated otherwise, the Intermediate Unit’s contract was not “voluntary” and, thus, it was entitled to invoke the doctrine of nullum tempus in response to the School District’s assertion that the statute of limitations barred its breach of contract action.

Section 5525 does not expressly apply its four-year contract limitation to government entities, so nullum tempus may exempt a qualifying government claim.

C. Carulli & B. Carulli, h/w v. N. Versailles Twp. Sanitary Auth. v. Port Vue Plumbing, Inc. · filed 2019-08-13

The four-year statute of limitations for contract actions does not expressly provide that it applies to actions brought by government entities.

Section 5525’s four-year limit for contract actions does not bar a Commonwealth agency’s action to vindicate public rights because the section does not expressly bind the Commonwealth or its agencies.

PA PUC v. Delaware Valley Regional Economic Dev. Fund · filed 2021-05-05

The parties are in agreement that section 5525 of the Judicial Code, 42 Pa.C.S. §5525, sets forth the four-year statute of limitations that would apply to the PUC’s claim for breach of contract, should nullum tempus not apply. It is both plain and undisputed that this statute contains no provision expressly rendering it applicable to the Commonwealth or its agencies.

Section 5525(8)’s four-year limit for actions based on a writing does not bar a municipality’s action to enforce strictly public rights under the nullum tempus doctrine.

Twp. of Salem v. Miller Penn Development, LLC Twp. of Salem v. Miller Penn Development, LLC · filed 2016-05-26(8)

Because the Township’s action sought to enforce strictly public rights, under the nullum tempus doctrine it is not subject to the statute of limitations.

Pennsylvania’s contract limitations period applies by analogy to a claim for benefits under an employee pension plan.

Ferguson v. Greyhound Retirement & Disability Trust · filed 1985-07-18

We believe that the claim is most analogous to contract law. ... Under Pennsylvania statute of limitations pertaining to contract law, the claims filed 9 months after the statute began to run, were timely.

Section 5525(8)'s four-year period for breach of contract applies to an ERISA benefits claim analogous to a contract claim.

Evans v. Sodexho · filed 2008-04-01(8)

While we find Evans' claim more analogous to a breach of contract claim, it does not change the outcome since the statute of limitations for breach of contract in Pennsylvania is four years.

Section 5525’s four-year limitation period for an oral contract claim is tolled when fraud or concealment causes the plaintiff to delay investigating the claim.

Greenberg v. Tomlin · filed 1993-03-11

Where, however, through intentional or unintentional fraud or concealment, the defendant causes the plaintiff to relax his vigilance or deviate from his right of inquiry into a prospective cause of action or where a contractual cause of action is a continuing one, the statute of limitations will be tolled.

A defendant whose conduct causes a plaintiff to delay inquiry may be estopped from invoking Section 5525(4)’s limitations bar.

United States Steel & Carnegie Pension Fund v. Decatur · filed 1987-05-26(4)

Faced with these pleadings, we find no error in the trial court’s conclusion that the defendants’ “conduct of affixing the pensioner’s name on his checks for sixteen years caused the plaintiff to relax its vigilance and deviate from its right of inquiry, estopping the defendants from invoking the bar of the statute.”

Section 5525’s four-year limitation period is not tolled by a promise to perform later when the defendant did not conceal the alleged breach.

Campbell, J. v. Dreger, A. v. Campbell, C. · filed 2019-06-07

The fact that he said he would make good on the promise in the future – i.e., after Andrew paid James in full – likewise did not hide the alleged breach or toll the statute of limitations.

Section 5525(3)'s four-year limitation is not an affirmative defense in an equity action; laches is the proper defense.

Fuisz v. Fuisz · filed 1989-08-28(3)

Next, appellant claims the four year statute of limitations of 42 Pa.C.S. § 5525(3), concerning contracts not founded upon an instrument in writing, applies to prohibit appellant’s cause of action. We find this argument to be without merit. The statute of limitations is not an affirmative defense in equity actions, the proper defense is a claim of laches.

Section 5525’s contractual limitations period does not control how far back a court may examine conduct in an equitable trust action.

In Re Francis Edward McGillick Foundation · filed 1991-07-05

Next, Trustees assert that the contractual limitations statute [42 Pa.C.S.A. § 5525] is most analogous to a written trust agreement, and so should limit the inquiry to the period 1983-1986. We do not agree.

Section 5525(3)’s four-year limitation applies to a contract claim against a hired real estate appraiser for a negligently prepared appraisal.

Sadtler v. Jackson-Cross Co. · filed 1991-01-31(3)

Section 5525(3), on the other hand, establishes a four year limitation for an “action upon an express contract not founded upon an instrument in writing.” ... We conclude, therefore, that appellants’ cause of action sounds in contract and must be governed by the statute of limitations applicable to contract actions.

Section 5525 gives contract actions, including claims for breach of an implied duty of good faith and fair dealing, a four-year limitation period.

AAMCO Transmissions, Inc. v. Harris · filed 1991-03-13

Hence, the appropriate statute of limitations is that governing contract actions. The Pennsylvania statute subjects contract actions to a four-year limitation period.

Section 5525 supplies a four-year limitations period for a diversity action to compel arbitration based on a contractual arbitration clause.

Painewebber v. Faragalli · filed 1995-08-04

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

Section 5525's four-year limitation period applies to a third party beneficiary's claim for breach of a deposit contract.

Melley v. Pioneer Bank, N.A. · filed 2003-10-21

Since we have concluded appellees had standing as third party beneficiaries to the deposit contract, and also that appellant breached that contract by failing to inquire into and abide by the court Orders, a four-year statute of limitations therefore, applies to this cause of action.

Section 5525(6) sets a four-year limit for actions on public officials’ bonds, but the court applied the former six-year limit to these earlier claims.

County of Somerset v. George · filed 1991-02-20(6)

However, the Judicial Code provides that any action upon any official bond of a public official must be commenced within four years. 42 Pa.C.S. § 5525(6). Formerly, the statute of limitations on such actions was six years. 42 Pa.C.S. § 5527(3). The current four year period was amended on December 20, 1982, to include actions on bonds, but did not take effect until 60 *96days thereafter.8 Accordingly, the six year statute of limitations is applicable herein.

Section 5525(6)’s four-year period for official bonds does not apply to a bankruptcy trustee’s bond because a bankruptcy trustee is not a public official, officer or employee.

United States Ex Rel. Century National Bank v. Nigro (In Re Louis Rosenberg Auto Parts, Inc.) · filed 1997-06-11(6)

However, because a bankruptcy trustee represents a select group of creditors and shareholders rather than the public at large, a bankruptcy trustee is not a public official, officer or employee.

Section 5525’s unexpired four-year period for a contract claim does not prevent a judgment of non pros for failure to prosecute.

Gates v. Servicemaster Commercial Service · filed 1993-09-28

The fact that the statute of limitations had not yet run on the plaintiffs breach of contract claim at the time the defendant’s motion for judgment of non pros was filed is of no moment.

Section 5525(7)’s four-year period for a note payable on a fixed date begins on that date.

Sovich v. Estate of Sovich · filed 2012-08-29(7)

The agreement, dated July 26, 1982, contains a date certain on which payment is due, which is five years from the date it was signed, or July 26, 1987. Thus, the statute of limitations began to run on July 26, 1987 pursuant to section 5525(7). Accordingly, Richard was required to bring an action to enforce his claim within four years of that date, on or before July 26,1991. He did not do so and, accordingly, his claim is time-barred.

Section 5525(7) provides a four-year limitation period for actions on negotiable or non-negotiable notes.

Springfield Oil Services, Inc. v. Costello · filed 1996-11-04(7)

Even if the Notes were not negotiable instruments, the applicable statute of limitations would be four years, as provided in 42 Pa.C.S.A. § 5525(7), rather than one year, as provided in 42 Pa.C.S.A. § 5523(2). Section 5525(7) applies to actions “upon a negotiable or non-negotiable bond, note or other instrument in writing.” 42 Pa.C.S.A. § 5525(7).

Section 5525(7) sets a four-year limitation period for actions on negotiable or nonnegotiable notes and similar written instruments.

Security National Bank v. Catlin Estate · filed 1997-10-16(7)

The Act of December 20, 1982, P.L. 1409, no. 326, art. II, §201, 42 Pa.C.S. §5525(7) provides that the statute of limitations for an “action upon a negotiable or nonnegotiable bond, note, or other similar instrument in writing ...” is four years.

For an instrument payable on demand, the four-year limitations period begins on the later of the last payment or the demand for payment.

Citizens Bank v. Lloyd, S. · filed 2015-12-29(a)(7)

Section 5525(a)(7) specifies that if the instrument is payable on demand, the limitations period begins at the later of either the last payment or the demand of payment.

Section 5525(a)(7) sets a four-year limitation period for actions on negotiable or nonnegotiable notes and similar written instruments.

Biondo, J. v. Lutfy, G. · filed 2018-12-28(a)(7)

The statute of limitations applicable to “[a]n action upon a negotiable or nonnegotiable bond, note or other similar instrument in writing” is four years.

Section 5525(a)(7) gives a plaintiff four years to bring an action to enforce a nonnegotiable note.

Witsen, B. v. Witsen, M · filed 2019-09-13(a)(7)

We conclude that the trial court correctly held that the Note was nonnegotiable and that Plaintiff’s action was therefore barred by the four-year statute of limitations of 42 Pa.C.S. § 5525.

Section 5525’s four-year contract limitation does not apply when the plaintiff seeks damages for personal injuries rather than contract damages.

Lancaster v. Petco Animal Supplies Inc. · filed 2009-04-28

In order to determine what statute of limitations applies, the two-year for negligence/personal injury or four-year for contract, an analysis of plaintiff’s claim and requested damages must be done. ... As plaintiff is seeking to only recover damages to her body, personal injuries, and not standard contract damages, the appropriate statute of limitations is two years per 42 Pa.C.S. §5524.

Section 5525’s four-year period does not govern a claim seeking damages for personal injuries under a commercial real estate lease, even when pleaded as a contract claim.

Ritchey v. Patt · filed 1994-01-13

Further, in his analysis, appellant alleges his claim under the commercial property lease is analogous to personal injury claims under Article 2 of the Uniform Commercial Code (UCC) in which the four-year statute of limitation (42 Pa.C.S. § 5525) has been prescribed. We find appellant’s argument to be without merit. ... We find these cases in no way analogous to a third-party beneficiary claim for personal injuries under a commercial real estate lease. Accordingly, appellant’s action is barred by the two-year statute of limitations.

Acknowledgment of a debt can revive it and prevent the four-year limitations period from barring enforcement.

David Cutler Industries, Ltd. v. Bank of America (In re David Cutler Industries, Ltd.) · filed 2013-11-19(a)

Based on this evidence, even if the Note was subject to a four (4) year statute of limitations, I conclude that the debt was revived by the acknowledgment doctrine and remained enforceable throughout the period, June 2007 to August 2009, during which the Debtor made payments to BOA on account of Darryl’s personal Mortgage.

Section 5525(a) provides a four-year period for breach of contract claims; partial payment tolls that period only when it clearly acknowledges the debt.

Asset Acquisition Group LLC v. DeJesus · filed 2010-04-06(a)

The parties agree that the applicable limitations period for this breach of contract claim is four years. 42 Pa.C.S. §5525(a). ... In order for a partial payment to toll the statue of limitations, the payment must constructively acknowledge the debt from which a promise to pay the balance is inferred. ... Based on the record before it, the court concludes the requirements of Huntingdon are not met and the statute of limitations is not tolled.

Section 5525(3)’s four-year period for an unwritten express contract is not tolled by negotiations to put the debt in writing without a clear acknowledgment of the debt.

Pagnotti v. Lehigh Valley Coal Sale Co. (In Re Pagnotti) · filed 2001-08-03(3)

I find that the four-year statute of limitations of 42 Pa.C.S.A. § 5525(3) has not been tolled through an acknowledgment of the debts.

A clear, unequivocal acknowledgment of a contract debt can toll Section 5525’s four-year limitation period until the debtor breaches the promise to pay or the parties sever their relationship.

Good v. Kantorik · filed 2003-04-11

Thus, under the “acknowledgment doctrine,” we must find, as a matter of law, that the defendant severed the agreement as of May 5, 2000, and that the statute of limitations began to run from the date the next payment was due under the agreement. Hence, as in Packer, taking the last undisputed date, May 5, 2000, and finding from the record that the plaintiff’s action was commenced on October 2, 2001, this action is not barred by the applicable four-year statute of limitations for contract actions.

The four-year limitations period restarts for a continuing, unconditional surety when the principal debtor makes a partial payment and the surety agreement covers that obligation.

Citicorp North America, Inc. v. Thornton · filed 1998-03-04(7)

Thus, Thornton-White’s partial payment on November 20, 1991, started anew the statute of limitations with respect to both Thornton-White, as principal debtor, and appellant, as continuing and unconditional surety.

An insurer’s partial payment does not toll Section 5525’s four-year period when it does not clearly acknowledge the debtor’s full debt.

Cole v. Lawrence · filed 1997-09-12

Under these circumstances, we decline to construe the insurer’s partial payment as a clear and unequivocal acknowledgement by appellee of the entire antecedent debt. Because the insurer’s payment did not constitute an acknowledgement of the existing debt, it does not toll the statute of limitations.

Payment of a contract debt’s principal removes the four-year limitations bar as to principal, but does not revive an interest claim unless the debtor acknowledges the interest obligation.

Huntingdon Finance Corp. v. Newtown Artesian Water Co. · filed 1995-06-13(1)

In light of this strict requirement, appellee unquestionably acknowledged its obligation with respect to the principal of the debt. There can be no more clear and unequivocal acknowledgement of debt than actual payment, thus removing the statute of limitations with respect to the principal. However, we agree with the trial court this acknowledgement does not extend to the corresponding interest.

Section 5525 sets a four-year limit for contract actions; an acknowledgment revives a barred debt only when both the acknowledgment and the debt identified are free from ambiguity.

Huntingdon Finance Corp. v. Newtown Artesian Water Co. · filed 1994-11-01(1)

The four year statute of limitations applicable in contract cases serves to protect prospective defendants from suffering continuing anxiety over the possibility of the commencement of an action against them in the future. Because the acknowledgment doctrine removes this protection, it is incumbent upon plaintiff to establish that both the acknowledgment and the identification of the debt are free from ambiguity. Plaintiff has failed to meet this burden with respect to the interest that accrued on the amount held by defendant prior to May 8, 1988. Due to the uncertainty of the identification of that debt, the claim for such interest was not revived by defendant’s payment to plaintiff on December 28, 1990.

A payment acknowledging an unsealed mortgage debt tolls the four-year period for bringing a foreclosure action under § 5525(a)(7).

Juniata Valley Bank v. Coffee Run Equity Assoc. · filed 2018-02-13(a)(7)

Thus, CREA’s acknowledgment of that debt by subsequent payment tolled the statute of limitations. See 42 Pa.C.S.A. § 5525(a)(7).

A confirmed plan promising to pay a debt acknowledges that debt and tolls the four-year limitations period; the period runs from a later default.

Keith A. Pierce · filed 2023-07-06(a)

Either way, Mr. Pierce misses the point: although a default marks when the statute of limitations begins to run, a confirmation order is an acknowledgement that the statute did not start before the confirmation date.

Section 5525(a)(3)’s four-year period for an express contract not in writing can be tolled by texts and payments that acknowledge the debt and imply a promise to pay the balance.

Tran, D. v. Le, H. · filed 2024-06-11(a)(3)

Here, in contrast to the son’s statement acknowledging that he borrowed money from his father in Gurenlian, we deem Appellant’s texts and payments in the case sub judice sufficient to toll the statute of limitations under the acknowledgment doctrine.

Section 5525(5)’s four-year limitation applies to arrearages under a registered foreign child support order; payments due more than four years before the enforcement action are barred.

Morrissey v. Morrissey · filed 1996-06-21(5)

A foreign judgment is subject to a four year statute of limitations. ... Thus we conclude that Mother’s action remains valid only with respect to arrearages that have accrued since April 20, 1991, because the action for enforcement of these obligations was brought within four years of the payment due date.

Section 5525(5)'s four-year limit for actions upon judgments does not bar registration and enforcement of a foreign support order under RURESA.

Morrissey v. Morrissey · filed 1998-06-16(5)

We conclude, therefore, that the four-year statute applicable to actions upon judgments does not bar registration and enforcement of the Texas support order pursuant to RURESA.

Section 5525(5) gives a creditor four years from the entry of a foreign judgment to register it in Pennsylvania under the Uniform Enforcement of Foreign Judgments Act.

National Union Fire Insurance v. Nicholas · filed 1994-12-15(5)

We, however, find that the four-year statute of limitations set forth at Section 5525(5) of the Judicial Code is applicable to proceedings under the UEFJA and that the limitations period commences to run on the date that the judgment is entered in the foreign state.

Section 5525’s four-year limitation period does not apply to the registration of foreign support judgments under UEFJA.

Stewart v. Stewart · filed 1999-12-22(5)

We find Appellant’s argument unpersuasive and conclude that the four-year statute of limitations enumerated in 42 Pa.C.S. § 5525 does not apply to the registration of foreign support judgments in Pennsylvania under UEFJA.

Section 5525(5)’s four-year limitation does not apply to the registration and enforcement of foreign equitable distribution and alimony judgments.

Bonfiglio v. Bonfiglio · filed 2001-07-24(5)

Accordingly, we hold that the trial court did not abuse its discretion or commit an error of law in determining that 42 Pa.C.S.A. § 5525(5) is inapplicable to the North Carolina judgments at issue.

The 1982 version of § 5525 does not govern a written construction contract claim that accrued in 1980.

Romeo & Sons, Inc. v. P.C. Yezbak & Son, Inc. · filed 1995-01-20

Yezbak, Romeo, and the courts below proceeded under the erroneous assumption that the current version of either section 5525 or section 5527, both of which were amended in 1982, governs this case.

Section 5525(7)’s four-year limitation period is satisfied when a plaintiff files an estate claim on time and is appointed executor after the period expires.

Lombardo v. Mellon Bank, N.A. · filed 1996-11-26(7)

Although not formally appointed executor until the trial began, appellee’s timely initiation of the suit and subsequent appointment as executor satisfies the statute of limitations for bringing this action.

For an underinsured motorists’ claim that cannot proceed without the insurer’s consent to settle, § 5525’s four-year period begins when the insurer provides its written waiver of subrogation rights.

Smith v. United States Fidelity & Guaranty Co. · filed 1998-12-17

The parties agree that the contractual four-year statute of limitation established by 42 Pa.C.S. §5525 governs this case but disagree as to the date when the four-year period began to run. ... Thus, we hold that the statute of limitations in this case began to run on October 14, 1993 when USF&G *390provided its written waiver of subrogation rights.

Section 5525(a)(8) gives plaintiffs four years to bring a breach of contract action or a related declaratory judgment action; the period for a UIM coverage claim begins when the insurer denies coverage.

WEGFAHRT v. ALLSTATE FIRE AND CAUSALTY INSURANCE COMPANY · filed 2019-11-25(a)(8)

Pennsylvania law provides for a four-year state of limitations on breach of contract actions and related declaratory judgment actions. ... A reasonable person, receiving Allstate’s correspondence, would have understood it to indicate that Allstate had made a coverage determination. At that point, the law required Plaintiffs to act in the next four years.

Section 5525 sets a four-year limitation period for promissory estoppel claims because they sound in contract law.

Crouse v. Cyclops Industries · filed 2000-01-28

Thus, as promissory estoppel makes otherwise unenforceable agreements binding, the doctrine sounds in contract law and we hold that, like other contract actions, the statute of limitations for a cause of action in promissory estoppel is governed by § 5525. Therefore, the Superior Court properly held that the limitations period where an agreement is enforceable under the doctrine of promissory estoppel is four years.

Section 5525’s four-year period does not apply to a statutory claim merely because the underlying transaction involved a written agreement.

Pantuso Motors, Inc. v. Corestates Bank · filed 2002-06-19

As an initial matter, Section 5525 can be eliminated from consideration. Although the underlying transaction that ultimately led to entry of the confession of judgment may have included an agreement reduced to writing, Pantuso’s claim under Section 8104 is founded upon the statute itself, and not upon a contract, bond, or other written instrument.

Section 5525’s four-year period applies to contract actions, not statutory insurance bad faith claims that sound in tort.

Ash v. Continental Insurance · filed 2003-09-15

This four-year limitation is applicable to actions in contract. 42 Pa.C.S. §5525. ... After reviewing the court decisions that have addressed this issue we conclude that a bad faith action under section 8371 sounds in tort and is subject to a two-year statute of limitations.

Section 5525(a) bars insurance contract claims filed more than four years after the insurer denies coverage or refuses to arbitrate.

Stockdale v. Allstate Fire & Cas. Ins. Co. · filed 2019-06-17(a)

The face of the Complaint demonstrates, however, that the statute of limitations bars claims in which an insurer denied coverage or refused to arbitrate because of the household exclusion prior to January 23, 2015-four years before Plaintiff filed this putative class action. Accordingly, putative class members' claims based upon a breach of an alleged insurance contract "by reason of the household exclusion" prior to January 23, 2015 are time-barred, and will be dismissed.

Section 5525’s four-year limitation period applies to contractual bad faith claims against an insurer because they are breach of contract claims.

HEALTH FLEET AMBULANCE, INC. v. MARKEL INSURANCE COMPANY · filed 2020-07-22

Therefore, while statutory bad faith claim are subject to a two-year statute of limitations, contractual bad faith claims are subject to the four- year statute of limitations applicable to breach of contract claims generally.

Section 5525’s four-year limitation period for a pension benefits claim begins when the borough denies the request for benefits.

Scavo v. OLD FORGE BOROUGH · filed 2009-08-05

As the record is void of any action by the Borough denying Scavo’s request for retirement benefits, we cannot state that Scavo’s complaint was filed beyond the four year statute of limitations. We note that the statute of limitations would only begin to run upon the Borough’s denial of benefits to Scavo, as Scavo would have no reason to appeal until after the Borough’s decision had been made.

Section 5525 gives a creditor four years to sue on an oral loan agreement, with the period running separately from each loan advance.

In re Elverson · filed 2013-05-15

Because the Petitioning Creditor did not advance the amount of her Claim pursuant to a single transaction but instead apparently hundreds of smaller transactions, the statute of limitations runs from each instance she wrote a check to the Proposed Debtor.

Section 5525(a)’s limitations period for a breach of contract claim begins when the claim accrues, on the date of the breach.

Metal Building Direct v. Renninger Construction · filed 2016-12-05(a)

In a breach of contract action, the limitations period begins to run on the date an action accrues, i.e. the date of the breach.

Section 5525(a) provides a four-year limitation period for breach of contract actions, measured from when the cause of action accrues.

Alumisource Corp. v. Kantner Iron & Steel · filed 2022-05-23(a)

The statute of limitations for an action asserting breach of contract is four years. See 42 Pa.C.S.A. § 5525(a). The limitation period is “computed from the time the cause of action accrued.” Fine v. Checcio, 870 A.2d 850, 857 (Pa. 2005). “[A] cause of action accrues when the plaintiff could have first maintained the action to a successful conclusion.” Id.

Section 5525's four-year limit for contract claims runs from when the claimant knew or should have known of the injury and its likely cause under the discovery rule.

Donovan v. Idant Laboratories · filed 2009-06-10

At that time, she knew or should have known that she had been injured and who had likely caused the injury. Thus, under the discovery rule, the date of discovery which caused the statutes of limitation to run was May 6, 1998. As this claim was filed in July 2008, the discovery rule does not toll the two-year statute of limitations for tort claims nor the four-year statutes of limitations for contract claims of Donna Donovan.

Section 5525(a) gives a breach-of-contract claim a four-year limitation period; constructive notice from a recorded deed can prevent discovery-rule tolling.

Wagner, C. v. Knapp, L. · filed 2014-10-14(a)

In this case, the deeds were recorded on three dates in the 1970s. The two- and four-year statutes of limitations thus expired decades ago. Appellants cannot toll the statutes of limitations through the discovery rule. The recording statute placed them on notice of the contents of the deed, and their failure to discover the injury at the time the deeds were recorded was unreasonable as a matter of law.

The discovery rule does not toll Section 5525(a)(3) when a claimant who transferred property under an alleged oral agreement cannot claim it was unaware of the alleged injury.

BR2D, LLC v. Feeko, K. and Feeko, J. · filed 2017-04-12(a)(3)

The discovery rule does not toll § 5525(a)(3) under these circumstances.

Section 5525 gives promissory estoppel and unjust enrichment claims a four-year limitations period, subject to the discovery rule when the injury could not reasonably have been discovered earlier.

West Chester University Foundation v. MetLife Insurance Co. · filed 2017-04-13

Pursuant to 42 Pa.C.S. § 5524, Plaintiffs fraud, fraud in the inducement, and negligent misrepresentation claims are subject to a two-year statute of limitations; pursuant to 42 Pa.C.S. § 8371, Plaintiffs bad faith claim is also subject to a two-year statute of limitations; and pursuant to 42 Pa.C.S. § 5525, Plaintiffs promissory estoppel and unjust enrichment claims are subject to a four-year statute of limitations. ... This Court finds that a reasonable review of the annual statements would not have alerted Plaintiff to the falsity of Defendant’s alleged statements regarding the vanishing premium scheme, and therefore concludes that only upon receipt of the November 2014 Lapse Notice was Plaintiff alerted to its injury. Because Plaintiff filed- the present action within a year of ascertaining its right to initiate and maintain suit, this Court finds that Plaintiff s claims are not procedurally barred by the applicable statutes of limitations.

Section 5525(a)’s four-year limit for contract suits may be tolled under the discovery rule without proof of fraud.

Charter Homes at Mill Creek v. Charlan Group · filed 2019-04-26(a)

Fraud need not be shown in order for a party to invoke the discovery rule.

Section 5525(a)(8) gives a breach of contract claim four years to be filed; under the discovery rule, the period is measured from when the injury was reasonably discoverable.

Gall, C. v. Gall, P. · filed 2023-03-27(a)(8)

Because the date she learned this information was within four years of the date upon which Ms. Gall filed her breach of contract claim in March 2013, that claim would then be timely under the discovery rule. 42 Pa.C.S.A. § 5525(a)(8) (four-year statute of limitation applies to breach of contract cause of action).

Section 5525 gives a plaintiff four years to bring a breach of contract claim against an insurance broker; here, the period began when the insurer denied coverage, and the discovery rule did not toll it.

Wasielewski, T. v. Goebel Insurance Agency · filed 2025-01-10

Because the discovery rule did not toll the statute of limitations, and there is no dispute of material fact that Erie denied coverage by June 14, 2018 at the latest, and Chung was aware of this denial, the statute of limitations began to run as of June 14, 2018. Four years from this date is June 14, 2022. The four-year statute of limitations thus expired on or about June 14, 2022.

Section 5525(a)(8) gives breach-of-contract claims a four-year limitations period; the discovery rule may delay accrual when the injury and its cause could not reasonably have been known.

WALDEN v. THE BANK OF NEW YORK MELLON CORPORATION · filed 2024-04-10(a)(8)

In Pennsylvania, the statute of limitations for breach of contract is four years, 42 Pa.C.S. § 5525(a)(8), and for claims under the UTPCPL is six years, 42 Pa.C.S. § 5527(b); Morse v. Fisher Asset Mgt., LLC, 206 A.3d 521, 526 (Pa. Super. 2019). ... Whether the Waldens knew or should have known through exercising reasonable diligence of their injury and its cause is a question of fact for the jury to decide.

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

WRIGHT v. ALLY FINANCIAL, INC. · filed 2025-09-17(8)

The statute of limitations for breach of contract claims is four years. 42 Pa.C.S.A. § 5525(8).

Section 5525’s four-year limitations period does not apply to bad-faith penalty claims under the Pennsylvania Prompt Pay Act; those claims have a two-year period.

Cecil Township Municipal Authority v. North American Specialty Surety Co. · filed 2011-12-15

In sum, the Mastercraft court concluded, the penalty and attorneys’ fees provision of § 3395 “does not provide a separate claim under tort, but allows additional damages on a contractual claim initiated under its provisions,” and thus the four-year statute of limitations under 42 Pa.C.S. § 5525 applied. ... We disagree with the reasoning of the Mastercraft court and believe the Pennsylvania Supreme Court would find that a bad faith claim brought under § 3395 is subject to a two-year statute of limitations period.

Section 5525 gives a plaintiff four years from the alleged loss to bring a breach of contract claim arising from a self-storage rental agreement.

Barr v. Public Storage · filed 2012-08-08

Here again, the plaintiff neglected to mention that the purported “impasse” between himself and Hertz claim management had been reached in March of 2009, or nine months before the four year statute of limitations on his *264breach of contract claim had expired on December 24, 2009.

Section 5525(3) gives a claim to recover an oral loan four years from accrual.

Miller v. Jannetta (In re Irwin) · filed 2014-04-15(3)

Miller’s claim based on the Companies Loan is an action to recover on a contract. In Pennsylvania,10 the statute of limitations for a breach of contract claim is four (4) years. 42 Pa.C.S. § 5525.11 ... Under either the “date of the loan” or the “reasonable period of time” approach, the limitations period expired before the commencement of this bankruptcy case.

Section 5525(a) sets a four-year limitations period for contract actions involving debts incurred in Pennsylvania.

Johns v. Northland Group, Inc. · filed 2014-12-31(a)

Since the debts here were incurred in Pennsylvania, 42 Pa.C.S.A. 5525(a) applies and sets a four-year period of limitations for actions arising in contract.

Section 5525(a)(3) and (8) impose a four-year limitations period on claims for unpaid telephone services.

In re Freeman · filed 2015-11-04(a)(3), (8)

The applicable statute of limitation in Pennsylvania is four (4) years. 42 Pa.C.S. § 5525(a)(3), (8).10 ... The claimant having failed to appear at the hearing to offer any further evidence on the issue, I find that the Debt- or has established that the statute of limitations expired on this claim prior to the filing of the bankruptcy case and therefore, the claim should be disallowed as unenforceable under applicable nonbankruptcy law.

Section 5525(a)(3)-(4) sets a four-year limitations period for claims based on an oral contract and for unjust enrichment.

Frost, M. v. Zeff, G. · filed 2015-12-11(a)(3)-(4)

The statute of limitations has run on the claims for breach of contract and unjust enrichment. See 42 Pa.C.S. § 5525(a)(3)-(4); Kakouras, 915 A.2d at 1153.

Section 5525(a) gives a plaintiff four years to bring an action upon a contract; adding a new contract claim after that period expires is untimely.

Pollock, R. v. National Football League · filed 2017-06-21(a)

Had Plaintiffs sought to amend their complaint to state contract claims at the time the case was transferred to state court, or at any time before February 2015, the statute of limitations would not have expired. See 42 Pa.C.S. § 5525(a) (providing a four-year statute of limitations for actions upon a contract). However, Plaintiffs waited more than two years after the transfer before they sought leave in April 2016 to add a contract claim.

Section 5525(a)(8) gives a party four years to bring a contract claim, measured here from the first missed payment.

Bloom, R. v. Bloom, R. · filed 2017-07-31(a)(8)

The statute of limitations applicable to a contract is four years. Id.; 42 Pa.C.S. § 5525(a)(8). ... Thus, Wife’s claim that Husband breached their agreement did not materialize until February 2012, when Wife’s February monthly payment was not made. ... Thus, Wife’s complaint was not barred by the applicable statutory period.

Section 5525(a) gives contract claims a four-year limitations period; each missed installment gives rise to a separate claim.

Chi. Title Ins. Co. v. Mazik (In re Mazik) · filed 2018-10-30(a)

Pennsylvania imposes a four (4) year statute of limitations on contract claims. 42 Pa.C.S.A. § 5525(a). ... For installment contracts, a new cause of action on each installment accrues when that installment is missed. ... Based on the allegations in the Complaint, neither Note was accelerated more than four (4) years before the commencement of the bankruptcy case. Therefore, I cannot conclude that the statute of limitations has run on Chicago Title's claim against the Debtor.

Section 5525 generally allows four years to bring a breach-of-contract claim; a finding that the claim is time-barred needs support for when the period began and when suit was due.

Rutkowski, S. v. Stenger, C. · filed 2018-11-30

Generally, the statute of limitations for a breach-of-contract claim is four years. Steiner v. Markel, 968 A.2d 1253, 1255, n.5 (Pa. 2009) (citing 42 Pa.C.S. § 5525). However, the trial court provided no discussion as to when the statute of limitations began to run and when Rutkowski should have filed a claim in order for it to have been timely. ... After review, we are constrained to agree with Rutkowski that the trial court’s cursory reference to the statute of limitations fails to explain or support the conclusion that her claim was barred.

Section 5525(a)’s four-year period for contract and implied-workmanship claims begins when the party owed the contractual duty knew or should have known of the breach, even if that party later assigns the claims.

Villas at Packer Condo Assn. v. JPG Group, Inc. · filed 2019-05-14(a)

We agree with the trial court that the statute of limitations began to run when Westrum, not Villas, became aware of the defect, since Levick had a contractual obligation to Westrum, not Villas. The four-year period to file suit ended on September 11, 2013.

Section 5525(a) gives breach of contract and unjust enrichment claims a four-year limitations period; filing a writ of summons tolls that period only with a good faith effort to serve it.

Hawley v. @home Builders, LLC · filed 2020-02-10(a)

Pennsylvania applies a four-year statute of limitations for claims based on breach of contract and unjust enrichment. ... Plaintiff’s approximately one-year delay in attempting to perfect service on Defendant does not constitute a good faith effort to serve Defendant with the Writ issued in March 2018, such that Plaintiff’s actions would work to toll the statute of limitations period.

Section 5525 gives a breach of contract claim a four-year limitations period.

Castro, D. v. Rosado, L. · filed 2020-03-04

“The statute of limitations for a breach of contract claim is four years.” Steiner v. Markel, 968 A.2d 1253, 1255 n.5 (Pa. 2009) (citing 42 Pa.C.S. § 5525). Four years after September 2013 was September 2017. Appellant commenced this action by complaint on August 23, 2016. Thus, the statute of limitations had not run by the time Appellant initiated this action.

Section 5525 gives breach of contract and promissory estoppel claims a four-year limitations period that begins when the alleged breach occurs.

PALMORE v. CLARION UNIVERSITY OF PENNSYLVANIA · filed 2022-12-08

The statute of limitations for breach of contract and promissory estoppel claims under Pennsylvania law is four years and begins to run at the time the contract or fiduciary duties are alleged breached.

Section 5525 gives four years to bring reformation, declaratory judgment, and unjust enrichment claims; the period begins when the injury occurs.

Harrington, S. v. Jeffers Farms, Inc. · filed 2023-09-26

Pennsylvania law dictates that complaints of reformation, declaratory judgment, and unjust enrichment “must be commenced within four years[,]” 42 Pa.C.S. § 5525; complaints of fraud and negligent misrepresentation “within two years[,]” 42 Pa.C.S. § 5524; and complaints of constructive trust “within five years[,]” 42 Pa.C.S. § 5526. ... Thus, Ann was injured in 1961 when she did not receive what she was entitled to under the resolution, and that is when the statute of limitations began to run.

Section 5525(4) gives breach of implied-in-fact contract and quantum meruit claims a four-year limitations period.

STANFORD HEALTH CARE v. HIGHMARK BLUE CROSS BLUE SHIELD · filed 2024-02-14(4)

A four-year statute of limitation governs Stanford’s breach of implied-in-fact contract and quantum meruit claims. See 42 Pa.C.S. § 5525(4).

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

D'Angelo, J. v. Morgan · filed 2023-12-19(a)(4)

Claims under RICO are subject to a four-year statute of limitations. ... Claims for unjust enrichment are subject to a four-year statute of limitations.

Section 5525(a)(4) provides a four-year limitations period that the court applied to Counts III through V.

Agere Systems, Inc. v. Advanced Environmental Technology Corp. · filed 2008-05-14(a)(4)

Under Pennsylvania law, Counts III, IV, and V are governed by a four-year statute of limitations period.

Section 5525(a)(8) gives claims for underinsured motorist benefits a four-year limitations period that begins when the insured settles with the underinsured driver; an insurer may be estopped from asserting the deadline if its misrepresentation induced the insured to delay filing.

Brittain v. National Casualty Co. · filed 2014-01-27(a)(8)

It is well-settled under Pennsylvania law that a four-year statute of limitations governs claims for UIM benefits. ... Consequently, and consistent with Rosenthal, Hopkins and Wilson, the Court concludes that Plaintiffs claim for UIM benefits accrued on November 6, 2008. ... Under these circumstances, Defendant’s conduct represents precisely the type of “inducement ... to delay bringing the action” that warrants the application of equitable estoppel.1 See Ciccarelli, 757 F.2d at 556; Nesbitt, 204 A.2d at 476.

Section 5525 gives a claimant four years after an insurer denies underinsured motorist coverage to file a breach of contract claim.

Devine v. Geico General Insurance Company · filed 2022-01-07

Defendant denied Plaintiff’s underinsured motorist claim on October 19, 2015. The statute of limitations for this claim therefore expired four years later, on October 19, 2019.

Section 5525(a)(8)’s four-year period for underinsured motorist claims begins when the insured settles with, or secures a judgment against, the underinsured driver.

Hopkins v. Erie Insurance · filed 2013-04-19(a)(8)

Here, applying Boyle and Rosen-thal, we hold that the four-year statute of limitations on underinsured motorist claims begins to run when the insured settles with, or secures a judgment against, the underinsured owner or operator.

Section 5525(8)’s four-year limit for contract actions does not bar a county action enforcing an obligation imposed by The County Code.

County of Beaver ex rel. Beaver County Board of Commissioners v. Sainovich · filed 2014-07-16(8)

Initially, we note that the appointment of a solicitor by a county must be in accordance with The County Code and it is those requirements that the County is seeking to enforce by bringing an action against Sainovich. This is not a breach of contract action. ... The County’s claim against Sainovich accrued to the County in its governmental capacity and the County is seeking to enforce an obligation imposed by The County Code.

Section 5525(a)(5) does not apply to a petition seeking to enforce a prior court order when no judgment was entered.

Strait, K. v. Schilling, C. · filed 2014-12-17(a)(5)

The language in 42 Pa.C.S. § 5525(a)(5), which Schilling argues is applicable, deals with an action on a judgment. Here, however, Strait was not initiating an action with her petition; rather, she simply sought to enforce a prior order. Moreover, there was no judgment entered in any court that would render section 5525(a)(5) applicable in this matter.

Section 5525(a)(5) gives a party four years to bring an action to enforce a judgment, including an action seeking to pierce the corporate veil.

SEVEN SPRINGS MOUNTAIN RESORT, INC. v. HESS · filed 2022-04-04(a)(5)

Under Pennsylvania law, “[a]n action upon a judgment or decree of any court of the United States or of any state” must be commenced within four years. 42 Pa. C.S.A. § 5525(a)(5). Insofar as Plaintiff seeks the equitable remedy of veil piercing based on Hess’s tortious misrepresentations, the state court judgment was entered in 2019, and thus the enforcement claim against Hess is timely.

Section 5525(a)(8) gives a party four years to seek a declaration of rights under a written contract; the period begins when an actual controversy exists, which need not await an insurer’s denial of coverage.

Selective Way Insurance v. Hospitality Group Services, Inc. · filed 2015-07-07(a)(8)

Although this Court in Wagner held that the four-year catchall statute of limitations contained in section 5525(a)(8) applies to declaratory judgment actions concerning the parties’ rights and duties under a written contract, the Wagner Court did not specify when the statute of limitations for such an action begins to run.8 ... For that reason, we disagree with Selective that Zourelias is instructive in the ease at bar and that the denial of coverage is the appropriate point to begin the limitations period for a declaratory judgment action filed by an insurance company. A, cause of action for a declaratory judgment accrues when an actual controversy exists between the parties.

Section 5525(a)(8)’s four-year period for a declaratory judgment action begins when an actual controversy arises; a letter discussing possible resolution without denying the claim does not trigger it.

Green v. Pennsylvania Property & Casualty Insurance Guaranty Ass'n · filed 2017-03-21(a)(8)

By itself, then, we are not convinced that PPCIGA’s 2007 letter demonstrates an actual controversy, or shows such contrary and antagonistic positions, that Appellant should have anticipated imminent or inevitable litigation against the association.

Section 5525(8) provides a four-year limitations period for declaratory judgment actions.

Ford, E. v. Oliver, J. · filed 2017-12-14(8)

This Court has held that a declaratory judgment action is subject to a four-year statute of limitations. ... The Fords initiated this suit on August 4, 2015, well after all applicable statutes of limitations expired.

Section 5525 imposes a four-year limitations period on declaratory judgment actions arising out of contract.

McWreath v. Range Resources Appalachia LLC · filed 2016-03-29

Finally, the McWreaths’ amendment would have been futile because the four-year limitations period for declaratory judgment- actions arising out of contract had run by the time the McWreaths commenced this lawsuit in 2013.

Section 5525(a) sets a four-year limitation period for contract actions and declaratory judgment actions concerning contractual rights.

B.A. D'Amour v. Lower Merion Twp. · filed 2019-08-30(a)

Thus, whether viewed as a declaratory judgment action or a contract action, Retirees’ Complaint is subject to a four-year statute of limitations.

Section 5525 applies a four-year limitations period to declaratory judgment actions.

Cavallo Mineral Partners v. EQT Production · filed 2025-03-13(8)

We agree with the trial court that Appellant’s declaratory judgment action was subject to a four-year limitations period.

Section 5525(8) gives a declaratory judgment claim four years; the period begins when an enforceable agreement creates an actual controversy, even if the agreed transfer occurs later.

Linde, B. v. Linde, E. · filed 2025-07-07(8)

In addressing her first issue, we first note that a declaratory judgment action, such as the one in the present matter, has a four-year statute of limitations. See Wagner v. Apollo Gas Co., 582 A.2d 364, 327 (Pa. Super. 1990); see also 42 Pa.C.S. § 5525(8). ... As such, we agree with the trial court that the execution of the document, itself, set into motion an “actual controversy,” Wagner, 582 A.2d at 327, as its enforceability was not contingent.

Section 5525(8) sets a four-year limitation period for declaratory judgment actions.

Kammerer, W. v. Kammerer, W. · filed 2019-05-01(8)

“This Court has held that a declaratory judgment action is subject to a four- year statute of limitations.” Ford v. Oliver, 176 A.3d 891, 899 (Pa. Super. 2017) (citing Wagner v. Apollo Gas Co., 582 A.2d 364, 366 (Pa. Super. 1990)); 42 Pa.C.S. § 5525(8).

Section 5525(a)(4) gives a claimant four years to bring an action based on an implied contract.

Konyk v. Pennsylvania State Police of the Commonwealth · filed 2016-01-12(a)(4)

Actions based on an implied contract or upon a judgment of any court in the United States are subject to a four-year statute of limitations. Section 5525(a)(4) and (a)(5) of the Judicial Code, 42 Pa.C.S. § 5525(a)(4), (5). Petitioner's right to file an action began either on December 20, 2012 when SORNA became effective or on January 15, 2013, when Petitioner was reclassified as a Tier 1 Offender. The Petition for Review was originally filed in this Court on October 14, 2014, less than two years later, clearly within the statute of limitations period.

Section 5525(a)(8) sets a four-year limitation period for an action upon a contract; dismissal of a court action to enforce arbitration does not toll that period.

Morse, J. v. Fisher Asset Management · filed 2019-03-15(a)(8)

The statute of limitations for an action upon a contract is 4 years. 42 Pa.C.S.A. § 5525(a)(8). ... Accordingly, the court’s May 13, 2010 order did not stay the 2009 action and did not toll the statute of limitations.

Section 5525 sets a four-year limitation period for contract actions.

in Re: Giant Eagle, Inc. · filed 2015-10-23

Pennsylvania's statute of limitations to file contract actions is four years.

Section 5525’s four-year limitation does not cover statutory accounting actions between co-owners of real property.

KEM Resources, LP v. Ryvamat, Inc. · filed 2022-07-13

The four-year statute of limitations, 42 Pa.C.S. § 5525, does not refer to actions seeking an accounting or actions concerning the rights of co-owners of real property.

A defense under § 5525(a) is waived if it is first raised in a post-trial motion rather than pleaded in new matter.

Johns, L. v. Hunt-Irving, L. · filed 2023-09-12(a)

Because Appellant failed to raise that defense in a new matter, his claim is waived.

Section 5525(a)(8)’s four-year period applies to actions on written contracts and does not cover claims of tortious interference with contracts.

M.J. Ameer v. Pottsville Code Enforcement and D. Chescavage · filed 2023-11-17(a)(8)

By contrast, a four-year statute of limitations applies to “[a]n action upon a contract, obligation or liability founded upon a writing . . . .” 42 Pa.C.S. § 5525(a)(8). ... However, he posits that because the interference was with contracts, the contract statute of limitations should apply. Simply stated, that is not the law.

Section 5525(a)(3)’s four-year period does not bar a claim for repayment when repayment was conditioned on the borrower having sufficient funds and demand was made within the period after that condition occurred.

In Re: Est. of F.G., Appeal of: Est. of F.G. · filed 2024-04-03(a)(3)

When the Estate obtained the settlement proceeds in the personal injury action, the condition precedent was met. Gitterman and Smolen then filed their notices of claims against the Estate, and thereby asserted their demands for repayment upon the first sign of an ability to pay. As those demands were made within the applicable four-year statute of limitations, the orphans’ court did not err in determining that the demands were not barred by section 5525(3).

Section 5525(a)(7)’s four-year limitation period did not bar a mortgage foreclosure action filed within months of the default.

Rubin, S. v. Kanya, S. · filed 2024-10-11(a)(7)

As the Estate filed a notice of default in May 2017, and filed suit in this case in August 2017, Insectarium failed to prove applicability of the statute of limitations defense. See 42 Pa.C.S.A. § 5525(a)(7).

Section 5525(7)’s four-year limit can bar an action on a note without preventing foreclosure on a mortgage securing the unpaid debt.

National Loan Investors v. Gold, B. · filed 2020-11-13(7)

Accordingly, the fact that the statute of limitations had expired for NLI to obtain an in personam judgment against the Golds on the note has no impact upon NLI’s standing to obtain an in rem judgment against the collateral that secured the unpaid debt.

Section 5525(4)’s four-year period for actions on contracts implied by law does not apply to employment discrimination suits under the PHRA.

Webster v. Great American Insurance · filed 1982-08-02(4)

The only remaining point which bears discussion is whether a suit under the PHRA does indeed fall within the residual provision or whether such a suit may be characterized as- an action for breach of a contract implied by law and therefore subject to the four-year limitation of 42 Pa.Cons.Stat. § 5525(4). On the basis of my decision in Clyde v. Thornburgh, supra, I conclude that plaintiff’s action falls within the six-year residual statute of limitations contained in 42 Pa.Cons.Stat. § 5527(6).