Sheriff Officers Assn. Inc. v County of Nassau, 21 Misc 3d 1130(A)
Typically an action for breach of contract is governed by a six-year statute of limitations. Here, however, the COB provides that "the President [of the Association] may initiate a grievance... within one (1) calendar year after the occurrence of the event grieved, provided it does not merely affect an individual." This, said Justice McCarty, “effectively shortens the statutory period set forth in CPLR 213(2) of six years to one year with regard to class action grievances brought by the president of plaintiff union....”
Accordingly, said the court, the period for which damages may be claimed with respect to this action is from one year prior to the filing of the grievance, to the present.
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