Alonzo W. Lawrence and James Simpson, Plaintiffs-Respondents v. Bauer Publishing & Printing Ltd., a Corporation…

Summary

The Supreme Court of New Jersey held that the one‑year statute of limitations for libel begins at the date of publication and that the discovery rule and equitable estoppel do not toll that period, so the plaintiffs' claims against City Administrator Joseph Hartnett are time‑barred and must be dismissed. The Court also affirmed that Rule 4:26‑4 allows a plaintiff to suspend the limitations period by filing a fictitious‑defendant complaint, which the plaintiffs failed to do.