Pennsylvania Consolidated Statutes

42 Pa. Cons. Stat. § 5531 (2026)

 No limitation.

✓ current as of May 2026
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§ 5531.  No limitation.

The following actions and proceedings may be commenced at any time notwithstanding any other provision of this subchapter except section 5521 (relating to limitations on foreign claims):

(1)  An action against an attorney at law by or on behalf of a client to enforce any implied or resulting trust as to real property.

(2)  An action by the Commonwealth, a county or an institution district against the real or personal property of persons who were public charges, including mental patients, to recover the cost of their maintenance and support.

(3)  An action by the Commonwealth, a county or an institution district against the real or personal property of persons who were legally liable to pay for the maintenance and support of persons who were public charges, including mental patients, to recover the cost of their maintenance and support.

 

Cross References.  Section 5531 is referred to in section 5527 of this title.

Notes of Decisions
Cited in 11 cases (2 in the last 5 years), 1982–2025 · leading case: Weinar, M. v. Lex, W., 176 A.3d 907 (Pa. Super. Ct. 2017).
Weinar, M. v. Lex, W., 176 A.3d 907 (Pa. Super. Ct. 2017). “See 42 Pa. C.S. § 5531 (only types.of civil actions not subject to a limitations period are a client’s action against an attorney to enforce an implied or resulting trust as to real property and an action by the Commonwealth or specified other government bodies to recover…”
In Re: Return of Pers. Prop. Appeal of: Commonwealth of Pennsylvania, by & through Twp. of Upper Darby, 180 A.3d 1288 (Pa. Commw. Ct. 2018). “42 Pa. C.S. § 5531. In light of our determination, we do not address the Township's remaining contentions.”
Simmons v. Cohen, 534 A.2d 140 (Pa. Commw. Ct. 1987). · cites it 2× “* *** 5 Petitioner responds by asserting that the applicable statute of limitations is either that contained in section 5531 of the Judicial Code, 42 Pa. C. S. §5531, 6 providing no limitation, or that contained in section 1411 of the Welfare Code, Act of June 13, 1967, P.”
Tigue v. Steger (In Re Tigue), 82 B.R. 724 (Bankr. E.D. Pa. 1988). “We believe that this remedy, as well as the underlying action, is therefore so closely related to be within the scope of 42 Pa.C.S. § 5531(1), and thus not be subject to any statute of limitations.”
Doyle v. Lipoff (In Re Penn Packing Co.), 42 B.R. 502 (Bankr. E.D. Pa. 1984). “, 42 Pa.Cons.Stat.Ann. § 5531(1) (Purdon 1981) (there is no time bar for commencing proceedings against an attorney by a client to enforce any implied or resulting trust as to real property.”
Cecil Twp. Mun. Auth. v. North Am. Specialty Sur. Co., 836 F. Supp. 2d 367 (W.D. Pa. 2011). “8 Contract and similar claims are subject to a four-year statute of limitations, 9 a few civil actions are exempt from any limitations period (42 Pa.C.S. § 5531), and a “catch-all” period applies to any civil action not specifically assigned to one of the enumerated periods (id.”
Commonwealth, Dep't of Transp. v. Rockland Constr. Co., 448 A.2d 1047 (Pa. 1982). “Appellees attempt to distinguish our decision in Bishop and Overmoyer on the ground that in enacting the statute of limitations at issue in this case, the Legislature also enacted a statute of limitations which states that no time limitation shall apply to actions brought by the…”
Fricker v. Corestates Bank, N.A. (In Re Fricker), 192 B.R. 388 (Bankr. E.D. Pa. 1996). “Clearly, the claims asserted do not fall within the very limited scope of 42 Pa.C.S. § 5531, which is applicable only to actions against attorneys to enforce trusts and certain actions by the Commonwealth.”
In Re: T. Frederick Motion for Return of Prop. -- Appeal of: Commonwealth of PA (Pa. Commw. Ct. 2018). “Additionally, none of the Section 5531 statutory exclusions applied to either the confiscation of the firearms in question or Frederick’s Petition for Return of 42 Pa. C.S. § 5531. 16 Additionally, the bail condition that prompted the confiscation of the firearms in the first…”
In re: Mighty Mouse, (1) Shitzu, & Henry Mason, (1) Maltese ~ Appeal of: L. Binakonsky (Pa. Commw. Ct. 2025). “Specifically, Appellant argued in her brief: 3 Section 5527(b) provides a “catch-all” statute of limitations for civil actions or proceedings that are neither expressly subject to another limitation period in the Judicial Code nor exempted from any limitation period pursuant to…”
In re: Mighty Mouse, (1) Shitzu, & Henry Mason, (1) Maltese ~ Appeal of: L. Binakonsky (Pa. Commw. Ct. 2025). “Specifically, Appellant argued in her brief: 3 Section 5527(b) provides a “catch-all” statute of limitations for civil actions or proceedings that are neither expressly subject to another limitation period in the Judicial Code nor exempted from any limitation period pursuant to…”
— 42 Pa. Cons. Stat. § 5531(1) — 2 cases
Tigue v. Steger (In Re Tigue), 82 B.R. 724 (Bankr. E.D. Pa. 1988). “We believe that this remedy, as well as the underlying action, is therefore so closely related to be within the scope of 42 Pa.C.S. § 5531(1), and thus not be subject to any statute of limitations.”
Doyle v. Lipoff (In Re Penn Packing Co.), 42 B.R. 502 (Bankr. E.D. Pa. 1984). “, 42 Pa.Cons.Stat.Ann. § 5531(1) (Purdon 1981) (there is no time bar for commencing proceedings against an attorney by a client to enforce any implied or resulting trust as to real property.”
— 42 Pa. Cons. Stat. § 5531(2) — 1 case
Commonwealth, Dep't of Transp. v. Rockland Constr. Co., 448 A.2d 1047 (Pa. 1982). “Appellees attempt to distinguish our decision in Bishop and Overmoyer on the ground that in enacting the statute of limitations at issue in this case, the Legislature also enacted a statute of limitations which states that no time limitation shall apply to actions brought by the…”
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