Nebraska Revised Statutes
Neb. Rev. Stat. § 30-2484 (2026)
Statutes of limitations
✓ current as of July 2026
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Unless an estate is insolvent the personal representative, with the consent of all successors, may waive any defense of limitations available to the estate. If the defense is not waived, no claim which was barred by any statute of limitations at the time of the decedent's death shall be allowed or paid. The running of any statute of limitations measured from some other event than death and advertisement for claims against a decedent is suspended during the two months following the decedent's death but resumes thereafter as to claims not barred pursuant to the sections which follow. For purposes of any statute of limitations, the proper presentation of a claim under section 30-2486 is equivalent to commencement of a proceeding on the claim.
Notes of Decisions
Cited in 9
cases (3 in the last 5 years), 1991–2025 · leading case: Sparks v. Mach, 993 N.W.2d 119 (Neb. 2023).
Sparks v. Mach, 993 N.W.2d 119 (Neb. 2023). “The 2-month suspension in Neb. Rev. Stat. § 30-2484 (Reissue 2016) means that by reason of a debtor’s death, 2 months is added to the nor- mal period of limitations before a debt is barred.”
In Re Est. of Cooper, 746 N.W.2d 653 (Neb. 2008). “In its analysis, the county court relied upon the probate code, Neb. Rev. Stat. § 30-2484 (Reissue 1995), and concluded that brown's filing of the claim on behalf of First Tennessee constituted the "commencement of a proceeding" on behalf of First Tennessee, and thus violated §…”
In re Est. of Lakin, 310 Neb. 271 (Neb. 2021). “23 22 Neb. Rev. Stat. § 30-2484 (Reissue 2016).”
Reid v. Evans, 733 N.W.2d 186 (Neb. 2007). “§ 25-207 (Reissue 1995), suspended by 2 months under Neb. Rev. Stat. § 30-2484 (Reissue 1995).”
Babbitt v. Hronik, 623 N.W.2d 700 (Neb. 2001). “§ 25-207 (Reissue 1995) (4-year limitation on personal injury claims) and Neb. Rev. Stat. § 30-2484 (Reissue 1995) (suspending statute of limitations under § 25-207 for 2 months following decedent’s death).”
Katskee v. Nevada Bob's Golf of Nebraska, Inc., 472 N.W.2d 372 (Neb. 1991). “Since the personal representatives cannot waive the defense without the consent of all the successors and failure to plead the nonclaim defense does not act as a waiver, the effect is to make proof of compliance with the claim procedure a condition precedent to, or an essential…”
Nat'l Bank of Com. Trust & Sav. Ass'n v. Otto, 606 N.W.2d 750 (Neb. 2000). “Neb. Rev. Stat. § 30-2484 (Reissue 1995) provides in part: “Unless an estate is insolvent the personal representative, with the consent of all successors, may waive any defense of limitations available to the estate.”
Johnson v. Antoniutti, 318 Neb. 465 (Neb. 2025). “In Nebraska, a negligence action such as this must be commenced within 4 years.”
Mulinix v. Roberts, 626 N.W.2d 220 (Neb. 2001). “[Mulinix] did not commence a proceeding until August 8, 1997 and, therefore, did not come within the applicable statute of limitations. ASSIGNMENT OF ERROR Mulinix assigns that the trial court erred in sustaining Roberts’ demurrer and dismissing Mulinix’s action on the basis of…”
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