On December 14, 2021, the First Department issued a decision in Lyman v. J.P. Morgan Chase & Co., 2021 NY Slip Op. 06954, holding that the statute of limitations for a claim of breach of a bailment contract runs from the date the plaintiff demanded the return of the bailed goods, explaining:
While the three-year statute of limitations for conversion accrued on the date the conversion occurred, not from the discovery of the conversion or the exercise of due diligence to discover, the six-year statute of limitations for breach of the bailment contract began to run when plaintiff demanded return of the stocks and defendants did not deliver them. Thus, the cause of action for breach of bailment contract is not time-barred.
(Internal citations omitted).