Every action at law for an injury to the person caused by the wrongful act, neglect or default of any person within this state shall be commenced within 2 years next after the cause of any such action shall have accrued.
Martinez v. Cooper Hosp.--Univ. Med. Ctr., 163 N.J. 45, 747 A.2d 266, 271 (2000). (The discovery rule was applied where the plaintiff was unaware that the decedent's death might have been caused by the defendant hospital's negligent failure to treat the decedent until after she received an anonymous letter informing her of that possibility and subsequently reviewed the decedent's medical records. The circumstances of the decedent's death, which was caused by peritonitis after a severe beating, were not by themselves sufficient to put the plaintiff on notice of the possibility of negligence.)
Baird v. American Medical Optics, 155 N.J. 54, 713 A.2d 1019, 1023 (1998) , overruling Lombardo v. Borsky, 298 N.J. Super. 658, 690 A.2d 150 (1997) , appeal dismissed, 153 N.J. 44, 707 A.2d 149 (1998). (The plaintiff had received an experimental intraocular lens implant, and the court held that her claims accrued shortly after the surgery, when she began suffering from multiple complications. Therefore, the plaintiff's claims of negligence and lack of informed consent, brought more than eight years after the surgery, were time-barred. The court observed that plaintiffs who were aware that they had been injured due to the fault of another should not be able to postpone the institution of a timely action merely by picking one theory of recovery over another.)
Bennett v. Surgidev Corp., 311 N.J. Super. 567, 710 A.2d 1023, 1026 (App. Div. 1998). (The plaintiff was aware or should reasonably have been aware of her malpractice claim shortly after the cataract surgery, during which intraocular lenses were implanted into her eyes, when the plaintiff became aware that the lens implanted during the cataract surgery was "not perfected," and was cause of her continuing ophthalmological problems.)
Procanik by Procanik v. Cillo, 97 N.J. 339, 478 A.2d 755 (1984). (A claim by parents for damages for emotional distress as a result of defects in their child, owing to the physician's negligence in failing to diagnose rubella in the woman in her first trimester of pregnancy, does not derive from an action by the child victim and was time-barred by the two-year statute.)
Lynch v. Rubacky, 85 N.J. 65, 424 A.2d 1169 (1981). (The statute of limitations in an action for the negligent reduction of a fracture begins to run when the plaintiff learns that such reduction was not properly performed. The plaintiff did not learn this until a second operation was performed (by another surgeon) to remove a pin inserted to stabilize the fracture in the first operation.)
Tyminski v. United States, 481 F.2d 257 (3d Cir. 1973). (The statute was tolled where the defendant persistently stated that the paraplegia was caused by the natural progression of a congenital lesion (arteriovenous angioma), rather than by the postoperative bleeding in the spinal cord. The failure to reoperate and stop the bleeding was found to be the proximate cause.)
Britt v. Arvanitis, 590 F.2d 57 (3d Cir. 1978) , applying New Jersey law. (In an action against the manufacturer of defective wire surgical sutures, the limitation period begins to run when it is first established that the sutures were causative factors in the plaintiff's damages.)