statute of limitations defense (New Jersey) · Go Syfert
← New Jersey issues

statute of limitations defense in New Jersey

77 New Jersey opinions name it 4 courts 1882–2026 12 in the last five years

The cases below were cited by New Jersey courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (33)

CaseFollowedCited
Williams v. Bell Telephone Laboratories, Inc.green
nj · 1993 · cited in 10 New Jersey opinions naming this issue, 2002–2025
2 sentences

2025Pointing to Williams v. Bell Telephone Laboratories, Inc., 132 N.J. 109, 118-20 (1993), Manar argues David waived the statute of limitations defense.

2024See Williams v. Bell Telephone Lab., Inc., 132 N.J. 109, 119-20 (1993) (holding where a statute of limitations defense is included as an affirmative defense in a pleading but the defense was not raised until after the trial, the defense is effectively waived).

610
Mason v. Nabisco Brands, Inc.green
njsuperctappdiv · 1989 · cited in 4 New Jersey opinions naming this issue, 2002–2023
2 sentences

2023Upon restoration of an action, the initial filing date is the operative date for application of the statute of limitations. "[I]f a defendant could not raise the statute of limitations defense prior to dismissal of the complaint, it cannot do so at the time it is restored." Mason v. Nabisco Brands, Inc., 233 N.J.

2002Upon compliance, however, the complaint would be restored without the break caused by the dismissal giving rise to a statute of limitations defense. [6] Id. at 268 , 558 A. 2d 851 .

34
Wilson v. Wal-Mart Storesgreen
nj · 1999 · cited in 2 New Jersey opinions naming this issue, 2019–2022
2 sentences

2022The doctrine is an equitable remedy that allows a plaintiff to "pursue a cause of action even after strict application of a statute of limitations would bar relief," Fox v. Millman, 210 N.J. 401, 416 (2012), and it "provides that when an A-4168-19 22 individual experiences a 'continual, cumulative pattern of tortious conduct, the statute of limitations does not begin to run until the wrongful action ceases,'" Roa v. Roa, 200 N.J. 555, 568 (2010) (quoting Wilson v. Wal-Mart Stores, 158 N.J. 263, 272 (1999)).

2019Under the doctrine, the statute of limitations does not begin to run until "a 'continual, cumulative pattern of tortious conduct . . . ceases.'" Roa, 200 N.J. at 566 (quoting Wilson v. Wal-Mart Stores, 158 N.J. 263, 272 (1999)).

22
Roa v. Roagreen
nj · 2010 · cited in 2 New Jersey opinions naming this issue, 2019–2022
2 sentences

2022The doctrine is an equitable remedy that allows a plaintiff to "pursue a cause of action even after strict application of a statute of limitations would bar relief," Fox v. Millman, 210 N.J. 401, 416 (2012), and it "provides that when an A-4168-19 22 individual experiences a 'continual, cumulative pattern of tortious conduct, the statute of limitations does not begin to run until the wrongful action ceases,'" Roa v. Roa, 200 N.J. 555, 568 (2010) (quoting Wilson v. Wal-Mart Stores, 158 N.J. 263, 272 (1999)).

2019As recognized in Cowell, a case involving claims brought under 42 U.S.C. § 1983 , the continuing violation doctrine is an equitable exception to the statute of limitations bar. 263 F.3d at 292; see also Roa v. Roa, 200 N.J. 555, 566 (2010).

22
Miller v. Estate of Kahngreen
njsuperctappdiv · 1976 · cited in 2 New Jersey opinions naming this issue, 1981–1989
2 sentences

1989The reason given is that "the action will ... revert to the pleadings in the status prevailing at the time of and just before the dismissal." Miller v. Estate of Kahn, 140 N.J.

1981Miller v. Estate of Kahn, 140 N.J.Super. 177, 182 (App.Div.1976).

22
White v. Karlssongreen
njsuperctappdiv · 2002 · cited in 4 New Jersey opinions naming this issue, 2002–2026
2 sentences

2026That case involved a defendant who filed numerous affirmative defenses, including a statute of limitations defense, without any "possible basis in fact" and without conducting any discovery aimed to support a statute of limitations defense. 354 N.J.

2026In White, the defendant admitted "[s]he did not recognize the possibility of a statute-of-limitations defense until shortly before trial." Id. at 290 .

14
Zaccardi v. Beckergreen
nj · 1982 · cited in 4 New Jersey opinions naming this issue, 1998–2023
2 sentences

1998In Zaccardi v. Becker, 88 N.J. 245 , 440 A.2d 1329 (1982), the Supreme Court, based upon the actions of both counsel, precluded defendant from asserting a statute of limitations defense.

1998In Zaccardi v. Becker, 88 N.J. 245 , 440 A.2d 1329 (1982), the Supreme Court, based upon the actions of both counsel, precluded defendant from asserting a statute of limitations defense.

14
Rappeport v. Flitcroftgreen
njsuperctappdiv · 1966 · cited in 3 New Jersey opinions naming this issue, 1993–2017
2 sentences

2017Super. 385 , 387 n. 1 (App. Div. 2000) (finding that "a statute of limitations defense is sufficiently akin to failure to state a claim as to permit its disposition by way of a motion under [Rule] 4:6-2(e)" where the facts alleged in the complaint are not in dispute); Rappeport v. Flitcroft, 90 N.J.

2000See, e.g., O'Connor v. Altus, 67 N.J. 106, 116 , 335 A. 2d 545 (1975); Rappeport v. Flitcroft, 90 N.J.Super. 578, 580-581 , 218 A. 2d 873 (App.Div.1966); Henry V.

13
Shepherd v. Hunterdon Developmental Centergreen
nj · 2002 · cited in 2 New Jersey opinions naming this issue, 2012–2026
2 sentences

2026Citing Shepherd v. Hunterdon Developmental Center, 174 N.J. 1 (2002), the judge found plaintiff's claims based on Cosgrove's conduct from 2015 through July 2017 were barred by the applicable two-year statute of limitations.

2012See Shepherd v. Hunterdon Developmental Ctr., 174 N.J. 1, 6-7 , 803 A.2d 611 (2002) (recognizing exception to two-year statute of limitations applicable to hostile work environment claim in which employee demonstrates pattern of continuing violations); see also Mancini v. Twp. of Teaneck, 179 N.J. 425, 431, 436-38 , 846 A.2d 596 (2004) (explaining that “[b]y definition, the continuing violation doctrine exposes a defendant to liability for acts that, standing alone, might have occurred outside the limitations period”).

12
Mancini v. Township of Teaneckgreen
nj · 2004 · cited in 2 New Jersey opinions naming this issue, 2012–2021
2 sentences

2021Laches "operates to bar a plaintiff from prosecuting all or part of an action based on acts occurring months or years earlier[.]" Mancini, 179 N.J. at 435 . "[W]hether laches should be applied depends upon the facts of the particular case and is a matter within the sound discretion of the trial [judge]." Id. at 436 (quoting Garrett v. General Motors Corp., 844 F.2d 559, 562 (8th Cir. 1988)).

2021Laches "operates to bar a plaintiff from prosecuting all or part of an action based on acts occurring months or years earlier[.]" Mancini, 179 N.J. at 435 . "[W]hether laches should be applied depends upon the facts of the particular case and is a matter within the sound discretion of the trial [judge]." Id. at 436 (quoting Garrett v. General Motors Corp., 844 F.2d 559, 562 (8th Cir. 1988)).

12
Morristown Associates v. Grant Oil Company (073248)green
nj · 2015 · cited in 2 New Jersey opinions naming this issue, 2019–2019
2 sentences

2019And we do not agree that the Supreme Court's rejection of a statute of limitations defense to the Spill Act, Morristown Assocs. v. Grant Oil Co. , 220 N.J. 360 , 106 A.3d 1176 (2015), supports plaintiffs' position.

2019And we do not agree that the Supreme Court's rejection of a statute of limitations defense to the Spill Act, Morristown Assocs. v. Grant Oil Co. , 220 N.J. 360 , 106 A.3d 1176 (2015), supports plaintiffs' position.

12
State v. United States Steel Corp.green
nj · 1956 · cited in 2 New Jersey opinions naming this issue, 1957–1978
2 sentences

1978See State v. United States Steel Corp., 22 N.J. 341, 357-360 (1956); Annotation, "Promises to Settle or Perform as Estopping Reliance on Statute of Limitations," 44 A.L.R. 3d 482 , 488, 505-506 (1972); cf. Allen v. Evesham Tp.

1957It was decided to let the question of the validity of the statute of limitations defense in the custody case abide the outcome of State v. United States Steel Corp., 22 N.J. 341 (1956), where the identical issue was presented.

12
Presslaff v. Robinsgreen
njsuperctappdiv · 1979 · cited in 1 New Jersey opinions naming this issue, 2026–2026
1 sentence

2026See Presslaff v. Robins, 168 N.J.

11
Fox v. Millmangreen
nj · 2012 · cited in 1 New Jersey opinions naming this issue, 2022–2022
1 sentence

2022The doctrine is an equitable remedy that allows a plaintiff to "pursue a cause of action even after strict application of a statute of limitations would bar relief," Fox v. Millman, 210 N.J. 401, 416 (2012), and it "provides that when an A-4168-19 22 individual experiences a 'continual, cumulative pattern of tortious conduct, the statute of limitations does not begin to run until the wrongful action ceases,'" Roa v. Roa, 200 N.J. 555, 568 (2010) (quoting Wilson v. Wal-Mart Stores, 158 N.J. 263, 272 (1999)).

11
Warren GARRETT, Appellant, v. GENERAL MOTORS CORPORATION, Appellee; Warren GARRETT, Appellee, v. GENERAL MOTORS CORPORATION, Appellantgreen
ca8 · 1988 · cited in 1 New Jersey opinions naming this issue, 2021–2021
1 sentence

2021Laches "operates to bar a plaintiff from prosecuting all or part of an action based on acts occurring months or years earlier[.]" Mancini, 179 N.J. at 435 . "[W]hether laches should be applied depends upon the facts of the particular case and is a matter within the sound discretion of the trial [judge]." Id. at 436 (quoting Garrett v. General Motors Corp., 844 F.2d 559, 562 (8th Cir. 1988)).

11
Juzwiak v. Doegreen
njsuperctappdiv · 2010 · cited in 1 New Jersey opinions naming this issue, 2017–2017
1 sentence

2017We have treated claims alleging harassment as causes of action for the intentional infliction of emotional distress, Juzwiak v. Doe, 415 N.J.

11
Parete v. Mullygreen
njsuperctappdiv · 1998 · cited in 1 New Jersey opinions naming this issue, 2010–2010
2 sentences

2010See also Parete v. Mully, 316 N.J.Super. 100, 102-03 , 719 A. 2d 702 (App.Div.1998).

2010See also Parete v. Mully, 316 N.J.Super. 100, 102-03 , 719 A. 2d 702 (App.Div.1998).

11
Kaczmarek v. New Jersey Turnpike Authoritygreen
nj · 1978 · cited in 1 New Jersey opinions naming this issue, 2005–2005
11
Hartsfield v. Fantinigreen
nj · 1997 · cited in 1 New Jersey opinions naming this issue, 2003–2003
11
Neel v. Magana, Olney, Levy, Cathcart & Gelfandgreen
cal · 1971 · cited in 1 New Jersey opinions naming this issue, 2001–2001
11
Higa v. Mirikitanigreen
haw · 1973 · cited in 1 New Jersey opinions naming this issue, 2001–2001
11
P.V.N. Acharya v. Carrollgreen
wisctapp · 1989 · cited in 1 New Jersey opinions naming this issue, 2001–2001
11
O'CONNOR v. Abraham Altusgreen
nj · 1975 · cited in 1 New Jersey opinions naming this issue, 2000–2000
11
Bank Leumi Trust Co. v. John Malasky, Inc.green
nyappdiv · 1985 · cited in 1 New Jersey opinions naming this issue, 1997–1997
11
Moors v. Hallgreen
nyappdiv · 1988 · cited in 1 New Jersey opinions naming this issue, 1997–1997
11
Rosenshein v. Rosensheingreen
nyappdiv · 1995 · cited in 1 New Jersey opinions naming this issue, 1997–1997
11
German v. Paulgreen
nyappdiv · 1995 · cited in 1 New Jersey opinions naming this issue, 1997–1997
11
State v. Muentnergreen
wis · 1987 · cited in 1 New Jersey opinions naming this issue, 1993–1993
11
Prickett v. Allardgreen
njsuperctappdiv · 1974 · cited in 1 New Jersey opinions naming this issue, 1993–1993
11
Prickett v. Allardgreen
nj · 1974 · cited in 1 New Jersey opinions naming this issue, 1993–1993
11
Tucker v. Stategreen
fla · 1984 · cited in 1 New Jersey opinions naming this issue, 1993–1993
11
Carlsen v. Masters, Mates & Pilots Pension Plan Trustgreen
nj · 1979 · cited in 1 New Jersey opinions naming this issue, 1984–1984
11
Biocraft Laboratories, Inc. v. USM Corporationgreen
njsuperctappdiv · 1978 · cited in 1 New Jersey opinions naming this issue, 1980–1980
11

Distinguished, questioned or overruled (1)

CaseNegativeCited
Redick v. Rohm & Haas Co.green
njsuperctappdiv · 1967 · cited in 1 New Jersey opinions naming this issue, 1995–1995
11

Also cited on this issue (46)

CaseCitedYears
Lopez v. Swyer green
nj · 1973
2 sentences

2010Typically, triggered by a defendant's motion for summary judgment or answer asserting a statute of limitations defense, the court will determine at a Lopez hearing prior to trial, when the plaintiff reasonably should have discovered that he or she had a cause of action. [6] Lopez, supra, 62 N.J. at 267 , 300 A. 2d 563 .

2010Typically, triggered by a defendant's motion for summary judgment or answer asserting a statute of limitations defense, the court will determine at a Lopez hearing prior to trial, when the plaintiff reasonably should have discovered that he or she had a cause of action. [6] Lopez, supra, 62 N.J. at 267 , 300 A. 2d 563 .

31998–2019
Russo Farms, Inc. v. Vineland Board of Education green
nj · 1996
2 sentences

2014Id. at 104-05 .

1997Russo Farm,s, Inc. v. Vineland Bd. of Educ., 280 N.J.Super. 320, 327 , 655 A.2d 447 (App.Div.1995), aff'd in part and rev’d in part, 144 N.J. 84 , 675 A.2d 1077 (1996).

21997–2014
W v. Pangborne & Co. v. New Jersey Department of Transportation green
nj · 1989
2 sentences

1998The Court accordingly considered whether DOT impliedly was obligated to “withhold a statute of limitations defense while its contractor cooperated in submitting a disputed claim to administrative review that DOT itself encouraged and subsequently controlled.” Id. at 560 , 562 A.2d 222 .

1998The Court accordingly considered whether DOT impliedly was obligated to “withhold a statute of limitations defense while its contractor cooperated in submitting a disputed claim to administrative review that DOT itself encouraged and subsequently controlled.” Id. at 560 , 562 A.2d 222 .

21998–2005
Fernandi v. Strully green
nj · 1961
2 sentences

1979Commencing with Fernandi v. Strully, 35 N.J. 434 (1961), our Supreme Court has recognized the so-called "discovery" *337 rule exception to a strict statute of limitations defense.

1971Under the so-called "discovery rule" of Fernandi v. Strully, 35 N.J. 434 (1961), for defendant to prevail on a statute of limitations defense it is not enough that a plaintiff knows of the injury for which claim is made as a residual of the purported offensive treatment, but he must know or have reason to know that such treatment was negligently administered.

21971–1979
M'iver, Lessees v. Ragan green
scotus · 1817
2 sentences

1961In Veghte , Justice Magie quoted a meaningful sentence from an early opinion [ McIver v. Ragan, 2 Wheat. 25 , 4 L.Ed. 175 ] by Chief Justice Marshall in a case involving what was claimed to be an inequitable result produced by a statute of limitations: "`If this difficulty be produced by the legislative power, the same power might provide a remedy, but courts cannot, on that account, insert in the statute of limitations an exception which the statute does not contain.'" ( 44 N.J.L., at p. 513 .) So it seems to me that, as a matter of broad principle, the majority has gone beyond the well estab

1961In Veghte , Justice Magie quoted a meaningful sentence from an early opinion [ McIver v. Ragan, 2 Wheat. 25 , 4 L.Ed. 175 ] by Chief Justice Marshall in a case involving what was claimed to be an inequitable result produced by a statute of limitations: "`If this difficulty be produced by the legislative power, the same power might provide a remedy, but courts cannot, on that account, insert in the statute of limitations an exception which the statute does not contain.'" ( 44 N.J.L., at p. 513 .) So it seems to me that, as a matter of broad principle, the majority has gone beyond the well estab

21882–1961
Shulas v. Estabrook green
njsuperctappdiv · 2006
1 sentence

2025The judge was required "to adequately explain, as required by R[ule] 1:7[-]4(a), why he permitted a voluntary dismissal . . . without imposing terms." Id. at 96 .

12025–2025
CKC CONDOMINIUM ASSOCIATION, INC. v. Summit Bank green
njsuperctappdiv · 2000
1 sentence

2021Ass'n v. Summit Bank, 335 N.J.

12021–2021
511 West 232nd Owners Corp. v. Jennifer Realty Co. green
ny · 2002
1 sentence

2021Declining to follow the unpublished case plaintiffs provided, the motion judge cited 511 W. 232nd Owners Corp. v. Jennifer Realty Co., 98 N.Y.2d 144 (N.Y. 2002).

12021–2021
Price v. New Jersey Manufacturers Insurance green
nj · 2005
1 sentence

2020Id. at 528 .

12020–2020
Freeman v. State green
njsuperctappdiv · 2002
1 sentence

2020Plaintiff contends "equitable tolling should be applied" because "a party should not be able to hide behind a statute of limitations defense when the lapse was due to the misconduct of the party asserting the defense," citing Freeman v. State, 347 N.J.

12020–2020
Pitney Bowes v. Baker Industries green
njsuperctappdiv · 1994
2 sentences

2015The Appellate Division rejected that argument and affirmed the trial court’s judgment in a published decision. *369 In doing so, the panel acknowledged Pitney Bowes, Inc. v. Baker Industries, Inc., 277 N.J.Super. 484 , 649 A.2d 1325 (App. Div.1994), in which the Appellate Division held that N.J.S.A. 2A:14-l.l’s ten-year statute of repose did not apply to bar a contribution action under the Spill Act, and that that reasoning had been applied in a 1999 unpublished decision to find a statute of limitations defense inapplicable to Spill Act contribution claims.

2015The Appellate Division rejected that argument and affirmed the trial court’s judgment in a published decision. *369 In doing so, the panel acknowledged Pitney Bowes, Inc. v. Baker Industries, Inc., 277 N.J.Super. 484 , 649 A.2d 1325 (App. Div.1994), in which the Appellate Division held that N.J.S.A. 2A:14-l.l’s ten-year statute of repose did not apply to bar a contribution action under the Spill Act, and that that reasoning had been applied in a 1999 unpublished decision to find a statute of limitations defense inapplicable to Spill Act contribution claims.

12015–2015
Montells v. Haynes green
nj · 1993
2 sentences

2015Although, as defendants argue, past case law does provide some basis to argue for the application of a default statute of limitations when a statute is silent on such defenses, see, e.g., Montells, supra, 133 N.J. 282 , 627 A.2d 654 , here the Spill Act is not silent.

2015Although, as defendants argue, past case law does provide some basis to argue for the application of a default statute of limitations when a statute is silent on such defenses, see, e.g., Montells, supra, 133 N.J. 282 , 627 A.2d 654 , here the Spill Act is not silent.

12015–2015
Ledbetter v. Goodyear Tire & Rubber Co., Inc. red
scotus · 2007
2 sentences

2010Id. at 657 , 127 S.Ct. at 2186 , 167 L.Ed. 2d at 1010 .

2010Id. at 657 , 127 S.Ct. at 2186 , 167 L.Ed. 2d at 1010 .

12010–2010
Barres v. Holt, Rinehart & Winston, Inc. green
njsuperctappdiv · 1974
12005–2005
Price v. New Jersey Mfrs. Ins. Co. neutral
njsuperctappdiv · 2004
12005–2005
Panzino v. Continental Can Company green
nj · 1976
12004–2004
Mancini v. Township of Teaneck neutral
njsuperctappdiv · 2003
12004–2004
O'Loughlin v. National Community Bank green
njsuperctappdiv · 2001
12003–2003
Taha v. DePalma green
njsuperctappdiv · 1986
12003–2003
Konopka v. Foster green
njsuperctappdiv · 2002
12003–2003
State v. Carroll green
nj · 1992
12001–2001
Jones v. Jones green
njsuperctappdiv · 1990
12001–2001
Byrd v. Manning neutral
njsuperctappdiv · 1992
12001–2001
Bowler v. Fidelity & Casualty Co. of NY green
nj · 1969
12001–2001
Bell v. Western Employer's Ins. Co. green
njsuperctappdiv · 1980
11999–1999
Unkert v. General Motors Corp. green
njsuperctappdiv · 1997
11998–1998
F.M.C. Stores Co. v. Borough of Morris Plains green
nj · 1985
11998–1998
Russo Farms, Inc. v. Vineland Board of Education green
njsuperctappdiv · 1995
11997–1997
Stockton v. Gristedes Supermarkets, Inc. neutral
nyappdiv · 1991
11997–1997
Bailey v. Central Vermont Railway, Inc. green
scotus · 1943
11996–1996
Sotomayor v. Allstate Ins. Co. green
njsuperctappdiv · 1994
11996–1996
LaBonte v. NEW YORK, NEW HAVEN & HARTFORD RAILROAD green
mass · 1960
11996–1996
Beneficial Finance Co. of Atl. City v. Swaggerty green
nj · 1981
11996–1996
Woolley v. Hoffmann-La Roche, Inc. green
nj · 1985
11993–1993
Erickson v. Marsh & McLennan Co. green
nj · 1990
11993–1993
Feil v. Senisi green
njsuperctappdiv · 1950
11993–1993
Fees v. Trow green
nj · 1987
11993–1993
Woolley v. Hoffmann-La Roche, Inc. green
nj · 1985
11993–1993
State v. McMeekin green
njsuperctappdiv · 1985
11993–1993
Lawrence v. Bauer Publishing & Printing Ltd. green
nj · 1979
11993–1993

Statutes the citing opinions construe

NJ § N.J. Stat. § 2A:14-1 (8) NJ § N.J. Stat. § 10:5-1 (4) NJ § N.J. Stat. § 10:5-12 (4) NJ § N.J. Stat. § 2A:14-2 (3) NJ § N.J. Stat. § 59:8-8 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

NY 423 (1894–2026) CA 395 (1864–2026) TX 189 (1940–2026) CT 184 (1909–2026) IL 177 (1887–2025) FL 173 (1972–2026) PA 165 (1904–2026) OH 136 (1939–2026) TN 131 (1984–2026) IN 128 (1862–2026) MI 123 (1901–2026) NC 99 (1884–2026) AL 81 (1891–2026) NJ 77 (1882–2026) IA 71 (1880–2026) AZ 70 (1969–2026) MS 67 (1877–2024) UT 58 (1906–2026) NM 58 (1946–2026) MO 48 (1978–2025) KS 48 (1905–2025) ME 46 (1982–2026) WA 46 (1985–2025) MA 46 (1931–2026) MN 46 (1894–2026) CO 45 (1976–2026) WI 45 (1884–2025) SC 44 (1922–2025) VA 40 (1906–2025) OR 40 (1917–2025) ID 38 (1977–2025) OK 36 (1875–2024) RI 35 (1890–2026) WV 33 (1902–2025) NE 32 (1982–2026) DC 30 (1978–2025) MD 30 (1944–2026) ND 28 (1912–2024) VT 24 (1996–2025) KY 24 (1917–2026) GA 24 (1848–2023) AR 24 (1914–2023) DE 20 (1987–2026) NH 20 (1993–2025) SD 16 (1912–2025) NV 16 (1979–2022) MT 16 (1933–2024) WY 12 (1925–2024) HI 10 (1967–2026) VI 10 (2002–2026) AK 10 (1987–2025) LA 5 (1967–2024)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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