The New Jersey Supreme Court issued a unanimous decision clarifying that false light invasion of privacy claims are subject to a one-year statute of limitations, matching the time limit for defamation lawsuits rather than the two-year period for personal injury claims. The ruling in *Salve Chipola, III v. Sean Flannery* resolves a critical question about timing requirements for privacy-based litigation in the state.
The case originated in January 2020 when plaintiff Salve Chipola attended a basketball game at Clearview Regional High School. Defendant Sean Flannery made statements to a school official alleging that Chipola was a drug dealer who had provided drugs and alcohol to students. When Chipola returned to the school for another game, a police officer prevented his entry and handed him a letter from the school administration banning him from school grounds.
Nearly two years after the incident, Chipola filed a lawsuit against Flannery for false light invasion of privacy. In his complaint, Chipola alleged that Flannery made false statements about him that harmed his reputation and caused emotional distress. The case raised fundamental questions about how courts should classify false light claims for purposes of determining applicable limitations periods.
Flannery moved to dismiss the complaint, arguing that Chipola had filed outside the applicable one-year statute of limitations that governs defamation claims. The defendant contended that false light invasion of privacy should be treated similarly to defamation for timing purposes, given the substantial overlap between the two causes of action.
The trial court agreed with Flannery's position and granted the motion to dismiss. The court relied on the precedent established in *Swan v. Boardwalk Regency Corp.*, a 2009 Appellate Division decision that had addressed similar timing issues for false light claims. The trial court's ruling effectively barred Chipola's lawsuit as untimely filed.
Chipola appealed the dismissal, but the Appellate Division affirmed the trial court's decision. The intermediate appellate court maintained that the one-year limitations period applied to false light claims, preventing Chipola from pursuing his case. Seeking further review, Chipola petitioned the New Jersey Supreme Court, which granted certification to resolve the statute of limitations question.
Justice Hoffman, writing for a unanimous Court, held that false light invasion of privacy claims are subject to the same one-year statute of limitations that applies to defamation claims. The Court emphasized the substantial overlap between false light and defamation causes of action, noting that both involve false statements that damage a person's reputation.
The Court explained that when a cause of action is created by common law or statute without an express limitations period, courts must determine which general limitations period applies. The decision process involves analyzing the nature of the claim and comparing it to established categories with defined time limits.
In reaching its conclusion, the Court considered practical considerations and free speech protections that inform limitations periods for speech-related torts. The Court noted that defamation and false light claims both involve expressive conduct that implicates First Amendment concerns, supporting the application of similar procedural requirements.
The ruling provides clarity for practitioners and litigants about timing requirements for false light claims in New Jersey. The decision ensures that individuals seeking to pursue false light invasion of privacy lawsuits must act promptly, filing their claims within one year of the alleged harmful conduct.
The Court's analysis reinforced the precedent established in the *Swan* decision, which had previously addressed the relationship between false light and defamation claims. By affirming this approach, the Court created consistency in how New Jersey courts handle timing issues for privacy-related litigation.
The decision has implications for how attorneys advise clients about potential false light claims. Legal practitioners must now ensure that clients understand the abbreviated timeline for filing such lawsuits, which provides less time than the two-year period typically available for personal injury claims.
For defendants facing potential false light litigation, the ruling provides additional protection by limiting the window during which they may face legal exposure. The shorter limitations period reduces uncertainty and encourages prompt resolution of disputes involving allegedly false statements.
The Court's unanimous decision reflects consensus about the appropriate treatment of false light claims within New Jersey's broader framework of limitations periods. The ruling balances the interests of protecting individual privacy rights with practical considerations about timely litigation and free speech protections.
The case was argued before the Court on Jan. 6, 2025, and decided on Aug. 7, 2025, following the Court's thorough consideration of the legal issues presented. The decision provides definitive guidance for future false light invasion of privacy cases in New Jersey courts.