In our Dec. 19, 2013, No-Fault Insurance Wrap-up column, we reported on the split in the Judicial Departments regarding the statute of limitations for commencing an action to recover no-fault insurance benefits against a self-insured. At that time, the First and Second Departments were split as to whether the applicable statute of limitations should be six years or three years. As the Court of Appeals has now resolved this question, we offer the following discussion.

Statute of Limitations