NJ Supreme Court: False Light Privacy Claims Face One-Year Defamation Statute of Limitations

New ruling aligns false light claims with defamation law, tightening the time to take legal action in New Jersey

Why This Case Matters

The New Jersey Supreme Court has drawn a bright line for false light invasion of privacy claims, stating that plaintiffs have just one year to bring suit, because the applicable statute of limitations for such cases is the same statute of limitations for defamation. This important decision could have critical consequences for anyone in New Jersey considering a false light invasion of privacy legal action - or preparing to defend against such a claim.

By finding that the statute of limitations was one year, rather than two, the Court made clear that these cases should be treated with the same urgency as defamation claims. For both sides of a dispute, the clock tick quickly, and there is little margin for delay.

Case Facts & Procedural History

The case, Salve Chipola, III v. Sean Flannery, was decided by the New Jersey Supreme Court on August 7, 2025, but started with a basketball game in January 2020. During halftime, Sean Flannery allegedly told a school official that Chipola was a drug dealer who had supplied drugs and alcohol to students. Later that day, the school banned Chipola from its premises.

Almost two years late, on December 12, 2021, Chipola filed a lawsuit claiming Flannery’s remarks placed him in a false light, damaging his reputation and causing emotional distress. The trial court dismissed the case, holding that the claim was filed outside the one-year statute of limitations applicable to defamation, and the Appellate Division agreed. When the dispute reached New Jersey’s highest court, the justices were asked to decide whether false light should be governed by a one-year or a two-year filing deadline.

NJ Supreme Court Analysis & Holding

In its August 7, 2025 opinion, the Court sided with the lower courts, ruling that false light invasion of privacy is so closely tied to defamation—both in the conduct it targets and the injury it addresses—that the two claims should share the same one-year statute of limitations.

The Court noted that both torts involve false statements or misleading portrayals that harm reputation and emotional well-being. It cited prior case law, including Rumbauskas v.

Cantor, 138 N.J. 173 (1994); McGrogan v. Till, 167 N.J. 414 (2001), and Romaine v. Kallinger, 109 N.J. 282, 294 (1988)., which recognized the “conceptual affinity” between the two causes of action. In aligning false light with defamation, the justices also pointed to national trends, observing that most jurisdictions treat false light claims under the same short limitations period.

In reaching its decision, the Court opined:

the conduct at the heart of both defamation and false light invasion of privacy claims is essentially the same; and holding otherwise would cause false light to engulf the tort of defamation and eradicate the narrowed one-year limitations period that is intended to balance potentially tortious behavior with free speech rights.

From a policy perspective, the Court expressed concern that allowing a longer time frame for false light would undermine the legislature’s intent in setting a shorter deadline for defamation, potentially chilling free speech and prolonging disputes over personal reputation. As such, the Court held that  N.J.S.A. 2A:14-3, which prescribes that defamation actions must be commenced within one year, is applicable to false light invasion of privacy claims. By confirming the one-year rule, the Court said it was promoting both legal consistency and the timely resolution of claims.

What This Means for You

For potential plaintiffs, the message is clear: wait too long, and you may lose the right to sue entirely. The countdown begins as soon as the false portrayal is published, leaving just twelve months to act. For defendants, the ruling provides an important procedural defense. If the claim is filed late, it can be dismissed without inquiry into the merits of the plaintiff's claim.

Why Legal Representation Is Crucial

Deadlines in the law are unforgiving, and even a single day’s delay can erase your claim or your defense. In matters involving privacy law or defamation, securing an attorney quickly ensures that the necessary evidence is preserved, procedural rules are met, and strategy is in place before time runs out.

Kemeny, Ramp & Renaud, LLC — Your NJ Privacy Law Advocates

At Kemeny, Ramp & Renaud, LLC, our attorneys are experienced in handling complex civil litigation involving privacy and defamation claims. We know how to act swiftly when deadlines loom and how to mount a strong defense when accusations arise.

If you believe you’ve been defamed or portrayed in a false light, or if you face such allegation, do not wait. Contact us today for a to protect your rights.