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Nebraska Revised Statutes

Neb. Rev. Stat. § 25-206 (2026)

Actions on oral contracts or statutory liabilities

✓ current as of July 2026
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An action upon a contract, not in writing, expressed or implied, or an action upon a liability created by statute, other than a forfeiture or penalty, can only be brought within four years.

Notes of Decisions
Cited in 58 cases (9 in the last 5 years), 1948–2026 · leading case: Weyh v. Gottsch, 303 Neb. 280 (Neb. 2019).
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Weyh v. Gottsch, 303 Neb. 280 (Neb. 2019). · cites it 2× “Neb. Rev. Stat. § 25-206 (Reissue 2016). Hike , supra note 5.”
Tilt-Up Concrete, Inc. v. Star City/Fed., Inc., 621 N.W.2d 502 (Neb. 2001). · cites it 3× “See Neb. Rev. Stat. § 25-206 (Reissue 1995). The dis *66 trict court sustained the demurrer, and Tilt-Up filed an amended petition.”
Krambeck v. City of Gretna, 254 N.W.2d 691 (Neb. 1977). · cites it 6× “The defendant contends that the 4-year statute of limitations found in section 25-206, R. R. S. 1943, is applicable and that plaintiffs’ claim for damages *612 was thus barred and the demurrer properly sustained by the District Court.”
Hike v. State, 297 Neb. 212 (Neb. 2017). · cites it 4× “34 See § 25-202 and Neb. Rev. Stat. § 25-206 (Reissue 2016). 35 Krambeck, supra note 26 , 198 Neb.”
City of Lincoln, Neb. v. Windstream Nebraska, Inc., 800 F. Supp. 2d 1030 (D. Neb. 2011). · cites it 18× “§ 86-704(4)(a)(i) provides that “[a] municipality shall not levy a tax, fee, or charge for any right or privilege of engaging in a telecommunications business .”
Susman v. Kearney Towing & Repair Ctr., 310 Neb. 910 (Neb. 2022). · cites it 5× “Kearney Towing filed a motion for summary judgment on the basis that the matter was barred by the 4-year statute of limitations “provided for oral contracts and as set forth in Neb. Rev. Stat. § 25-206 .” As part of this motion, Kearney Towing filed a statement of undisputed…”
Jenkins v. Gen. Collection Co., 538 F. Supp. 2d 1165 (D. Neb. 2008). · cites it 2× “” Neb.Rev.Stat. § 25-206 (Reissue 1995). An “action upon .”
Brtek v. Cihal, 515 N.W.2d 628 (Neb. 1994). · cites it 2× “§ 25-202 (Reissue 1989) provides in part: “An action for the recovery of the title or possession of lands, tenements or hereditaments, or for the foreclosure of mortgages thereon, can only be brought within ten years after the cause of action shall have accrued____” An action…”
Trausch v. Hagemeier, 313 Neb. 538 (Neb. 2023). · cites it 2× “§ 25-209 (Reissue 2016) (action on official or judicial bond), Neb. Rev. Stat. § 25-206 (Reissue 2016) (action on statutory liability), and § 25-207(4) (fraud).”
Eddie Chambers, Appellant, v. Omaha Pub. Sch. Dist. Et Al., Appellee, 536 F.2d 222 (8th Cir. 1976). · cites it 2× “Plaintiff alludes to the disparity between § 25-219, which sets up a three-year statute of limitations for actions based upon a federal statute, and Neb.Rev. Stat. § 25-206, which establishes a four-year statute of limitations for actions based upon liability created by state…”
Sodoro, Daly & Sodoro, P.C. v. Kramer, 679 N.W.2d 213 (Neb. 2004). · cites it 2× “ANALYSIS The parties agree that the statute of limitations at issue in this case is Neb. Rev. Stat. § 25-206 (Reissue 1995), which provides that “[a]n action upon a contract, not in writing, expressed or implied .”
T. S. McShane Co. v. Dominion Constr. Co., 278 N.W.2d 596 (Neb. 1979). · cites it 2× “The parties are in agreement that an action can only be brought on a verbal contract within 4 years and that section 25-206, R. R. S. 1943, is applicable.”
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