The statute of limitations for breach of a promissory note payable in installments is six years. A default on a single installment payment does not trigger the running of the statute on the entire debt. Instead, separate causes of action accrued as installments of the loan indebtedness are due and payable. Installment payments that have accrued more than six years prior to commencement of the action are time-barred.
Cannell v. Grail Partners, LLC, NY Slip Op 00973 (1st Dep't February 11, 2020)
Here is the decision.
