Neb. Rev. Stat. » Chapter 25
Nebraska Revised Statutes

Neb. Rev. Stat. § 25-222 (2026)

Actions on professional negligence

✓ text as last checked Oct. 2026 (this copy records no edition or section history)
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Any action to recover damages based on alleged professional negligence or upon alleged breach of warranty in rendering or failure to render professional services shall be commenced within two years next after the alleged act or omission in rendering or failure to render professional services providing the basis for such action; Provided, if the cause of action is not discovered and could not be reasonably discovered within such two-year period, then the action may be commenced within one year from the date of such discovery or from the date of discovery of facts which would reasonably lead to such discovery, whichever is earlier; and provided further, that in no event may any action be commenced to recover damages for professional negligence or breach of warranty in rendering or failure to render professional services more than ten years after the date of rendering or failure to render such professional service which provides the basis for the cause of action.

Notes of Decisions
Cited in 139 cases (13 in the last 5 years), 1974–2025 · leading case: Sacchi v. Blodig, 341 N.W.2d 326 (Neb. 1983).
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Sacchi v. Blodig, 341 N.W.2d 326 (Neb. 1983). · cites it 60× “Blodig and the Hospital filed separate motions for summary judgment, and each claimed that Sacchi's cause of action was barred by the statute of limitations under Neb.Rev.Stat. § 25-222 (Reissue 1979). The trial court sustained the motions for summary judgment, and Sacchi…”
Tylle v. Zoucha, 412 N.W.2d 438 (Neb. 1987). · cites it 56× “The district court judge granted the motion for summary judgment on the basis that the suit against Zoucha was not brought within the applicable statute of limitations governing actions for professional negligence under Neb.Rev. Stat. § 25-222 (Reissue 1985). Zoucha was also…”
Schendt v. Dewey, 520 N.W.2d 541 (Neb. 1994). · cites it 58× “Dewey's demurrer to each of the petitions alleged that the corresponding petition failed to state a cause of action because the petition was barred by Neb.Rev.Stat. § 25-222 (Reissue 1989) and the action was not brought within 10 years of the alleged negligence.”
Wehrer v. Dynamic Life Therapy & Wellness, P.C., 926 N.W.2d 107 (Neb. 2019). · cites it 30× “The district court granted summary judgment on the ground that the customer's cause of action was time barred by the statute of limitations for professional negligence under Neb. Rev. Stat. § 25-222 (Reissue 2016). FACTS On February 17, 2017, Arlys Wehrer filed a negligence…”
Colwell v. Mullen, 918 N.W.2d 858 (Neb. 2018). · cites it 13× “The district court granted Mullen's motion for summary judgment, concluding that Colwell's malpractice claims were barred by the statute of limitations set forth in Neb. Rev. Stat. § 25-222 (Reissue 2016). We affirm.”
Reinke Mfg. Co. v. Hayes, 590 N.W.2d 380 (Neb. 1999). · cites it 26× “(Reinke), appeals from an order granting summary judgment to appellee, Edward David Hayes, doing business as E-H Engineering (Hayes), on the basis that Reinke’s claims were barred by the 2-year statute of limitations applicable to professional negligence, Neb. Rev. Stat. §…”
Jorgensen v. State Nat'l Bank & Trust Co., 583 N.W.2d 331 (Neb. 1998). · cites it 36× “This appeal presents a question whether "retirement planners" are "professionals" within the meaning of Neb.Rev.Stat. § 25-222 (Reissue 1995). We conclude that the retirement planners in the instant case are not professionals and that they did not render professional services;…”
Churchill v. Columbus Comm. Hosp., 830 N.W.2d 53 (Neb. 2013). · cites it 21× “Actions for damages arising out of the pro- fessional services provided by physical therapists are actions based on an alleged claim of negligence in providing professional services and are subject to the time limitations described in Neb. Rev. Stat. § 25-222 (Reissue 2008). 7.”
Georgetowne Ltd. P'ship v. Geotechnical Servs., Inc., 430 N.W.2d 34 (Neb. 1988). · cites it 23× “After an evidentiary hearing, the district court dismissed *25 plaintiff’s second amended petition for the reason that the action was barred by the statute of limitations governing professional services set forth in Neb. Rev. Stat. § 25-222 (Reissue 1985). The trial court…”
Rosnick v. Marks, 357 N.W.2d 186 (Neb. 1984). · cites it 20× “The district court sustained a demurrer and dismissed the action on the ground that any cause of action for professional negligence was barred by Neb. Rev. Stat. § 25-222 (Reissue 1979). We affirm.”
Bd. of Regents of the Univ. of Nebraska v. Wilscam Mullins Birge, Inc., 433 N.W.2d 478 (Neb. 1988). · cites it 17× “The district court for Douglas County held that the action was one for professional negligence and was barred by Neb. Rev. Stat. § 25-222 (Reissue 1985). The University timely appealed and, in this court, sets out four assignments- of error, alleging the district court erred in…”
Egan v. Stoler, 653 N.W.2d 855 (Neb. 2002). · cites it 8× “The district court granted summary judgment in favor of Stoler on the basis that the 2-year statute of limitations under Neb. Rev. Stat. § 25-222 (Reissue 1995) for professional negligence had expired.”
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