New Hampshire Revised Statutes

N.H. Rev. Stat. Ann. § 508:2 (2026)

Real Actions

✓ current as of May 2026
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    508:2 Real Actions. –
I. No action for the recovery of real estate shall be brought after 20 years from the time the right to recover first accrued to the party claiming it or to some persons under whom the party claims.
II. No action for the recovery of real estate pursuant to rights based on a possibility of reverter, right of re-entry, or executory interest shall be brought after 5 years from the time the right to recover possession or the right of re-entry first accrued to the party claiming it or to some persons under whom the party claims.

Source. RS 181:1. CS 192:1. GS 202:1. GL 221:1. PS 217:1. PL 329:1. RL 385:1. 2008, 228:3, eff. Jan. 1, 2009.

Notes of Decisions
Cited in 31 cases (5 in the last 5 years), 1969–2025 · leading case: Plaisted v. LaBrie, 70 A.3d 447 (N.H. 2013).
Plaisted v. LaBrie, 70 A.3d 447 (N.H. 2013). · cites it 7× “154 (1978), her claim for the proceeds from the sale of the property was based upon her ownership interest in the property, and, thus, the twenty-year statute of limitations for the recovery of real estate applied.”
O'Hearne v. McCLAMMER, 42 A.3d 834 (N.H. 2012). · cites it 5× “In its narrative order, the trial court declined to interpret the parties’ deeds, but instead ruled that McClammer’s claims were barred by the twenty-year statute of limitations set forth in RSA 508:2 (2010), which the court determined had been triggered either by the legal…”
Jenot v. White Mountain Acceptance Corp., 474 A.2d 1382 (N.H. 1984). · cites it 5× “Feltham argued that as the current sole owner of White Mountain’s assets, he had the right to enforce collection of the promissory note, under the provisions of RSA 508:2 and RSA 508:6, beyond the three-year continuance period.”
Cadle Co. v. Dejadon, 904 A.2d 605 (N.H. 2006). · cites it 5× “See RSA 508:2 (1997). The trial court ruled that “the 1993 foreclosure served to effectively discharge the mortgage by operation of law.”
Del Norte, Inc. v. Provencher, 703 A.2d 890 (N.H. 1997). · cites it 3× “The trial court held that the plaintiff was not entitled to the twenty-year statute of limitations provided for actions upon notes secured by mortgages, see RSA 508:2, :6 (1997), because foreclosure of the first mortgage extinguished Mundaca’s rights under the second mortgage.”
Boston v. Sprague Energy Corp., 861 A.2d 781 (N.H. 2004). · cites it 4× “For its part, Sprague argues on cross-appeal that the trial court erred: (1) in denying its motion for summary judgment and ruling that B&M’s claims regarding the removal of its railroad track by Sprague were governed by the twenty-year statute of limitations for the recovery of…”
West Gate Vill. Ass'n v. Dubios, 145 N.H. 293 (N.H. 2000). · cites it 2× “West Gate contends that the law of the case does not apply, and, even if RSA 508:4, I, does apply, the amended covenants provide for a six-year period within which to bring a collection action.”
Sundell v. Town of New London, 409 A.2d 1315 (N.H. 1979). “RSA 508:2. Thus, insofar as the trial court here instructed the jury that damages could be recovered only for injury to the plaintiffs’ property occurring within six years prior to the commencement of these actions, the defendant cannot complain.”
Hewes v. Bruno, 424 A.2d 1144 (N.H. 1981). · cites it 2× “The Superior Court (Batehelder, J.) granted the Brunos’ request for a finding of fact that they and their predecessors in title have treated the disputed land as if it were their own for a period exceeding twenty years, the statutory period for acquiring title by adverse…”
Premier Capital, LLC v. Skaltsis, 934 A.2d 496 (N.H. 2007). · cites it 2× “” Read in conjunction with RSA 508:2 (1997), which provides that “[n]o action for the recovery of real estate shall be brought after 20 years from the time the right to recover first accrued,” RSA 508:6 “establishes a twenty-year statute of limitations for notes secured by…”
St. Onge v. Zuccola (In Re St. Onge), 317 B.R. 39 (Bankr. D.N.H. 2004). · cites it 2× “” N.H.Rev.Stat. Ann. § 508:6 (1997). Thus, because mortgage proceedings are governed by a twenty-year statute of limitations, as a matter of law, the Defendant is permitted to assert his rights under the note and the mortgage.”
Doggett v. Town of North Hampton Zoning Bd. of Adjustment, 645 A.2d 673 (N.H. 1994). “, RSA 508:2 (1983) (real actions); RSA 508:4 (Supp.”
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