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Court Upholds Strict Two-Year Statute of Limitations for Motor Vehicle Accidents (PA)

December 6, 2019

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<p style="text-align: justify;">On November 27, 2019, the Superior Court of Pennsylvania affirmed the trial court’s granting of Appellee’s motion for summary judgment in <em><a href="">Harry Martin v. John Seedorf</a></em><em>.</em> The Court reaffirmed that the date of a motor vehicle accident is the start date for the statute of limitations and learning of new more serious injuries does not alter the strict two-year limit on filing negligence claims.</p>
<p style="text-align: justify;">On February 13, 2016, Harry Martin was involved in a motor vehicle accident.  A police report stated that Martin had a suspected minor injury.  However, on or about March 7, 2016, Martin began to have excruciating pain in his right wrist.  Due to Martin’s unique physiology, the accident led to an unexpected and unnatural accelerated version of Kienbock’s Disease.  Martin then commenced an action against Appellee, John Seedorf, on February 22, 2018.  Seedorf raised the statute of limitations as an affirmative defense and filed for a motion for summary judgment.  Martin argued that the statute of limitations did not begin running until March 7, 2016, when he learned that his injury was more significant than he originally understood it to be.  The trial court granted Seedorf’s motion for summary judgment and Martin appealed.</p>
<p style="text-align: justify;">The Court explained that the statute of limitations to recover for negligence is two years.  In motor vehicle accidents, the statute of limitations begins to run on the date of the accident.  Lack of knowledge of the full extent of an injury does not alter the statute of limitations.  Therefore, the Court ruled in favor of Seedorf and upheld the trial court’s decision to grant the motion for summary judgment.</p>
<p style="text-align: justify;">This case furthers the importance of checking when an accident occurred and when the plaintiff is attempting to file their claims.  There are very narrow exceptions for a plaintiff to get around the strict two-year statute of limitations in negligence suits, but more than likely if a plaintiff files two-years after the accident, they are time-barred.</p>
<p style="text-align: justify;">Thanks to Nick Wight for his contribution to this post.  Please email <a href="">Georgia Coats</a> with any questions.</p>


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