An action upon a contract, not in writing, expressed or implied, or an action upon a liability created by statute, other than a forfeiture or penalty, can only be brought within four years.
§ 25-206.Actions on oral contracts or statutory liabilities.
Article 2: Limitation of Actions · Not amended since original codification · Last verified July 22, 2026
In one sentenceThis section sets a four-year deadline for actions on contracts that aren’t in writing, whether express or implied, and for actions on a liability created by statute, other than a forfeiture or penalty.
Full Text of § 25-206
Source
R.S.1867, Code § 11, p. 395; R.S.1913, § 7568; C.S.1922, § 8511; C.S.1929, § 20-206; R.S.1943, § 25-206.
Plain-English Summary
Not every agreement gets written down, and Nebraska gives oral and implied contracts a shorter window than their written counterparts. Section 25-206 covers a contract not in writing — express or implied — with a four-year deadline, one year shorter than the five years section 25-205 gives written contracts.
The same four-year period covers a different category entirely: actions on a liability that a statute creates, rather than one arising from an agreement between the parties. That statutory-liability piece has its own carve-out — the four years doesn’t apply to a forfeiture or a penalty, which typically follow their own, often shorter, statutory deadlines.
Frequently Asked Questions
How long do I have to sue for breach of an oral agreement in Nebraska?
Four years, under section 25-206, whether the oral contract is express or implied.
Does this section cover implied contracts as well as spoken agreements?
Yes. It applies to any contract not in writing, whether express or implied, without distinguishing between the two for purposes of the four-year period.
What does “liability created by statute” mean here?
It refers to an obligation that arises because a statute imposes it, rather than one created by an agreement between the parties, and it also gets a four-year deadline unless it’s a forfeiture or penalty.
How is this different from the five-year deadline in section 25-205?
Section 25-205 governs written contracts and gives five years. Section 25-206 governs contracts not in writing and statutory liabilities other than forfeitures or penalties, giving four years instead.
Does this four-year deadline apply to a statutory penalty or forfeiture?
No. Section 25-206 specifically excludes forfeitures and penalties from its four-year period for statutory liabilities.
Source & verification. Section text and the amendment-history citation are
reproduced verbatim from the Nebraska Legislature, Revisor of Statutes, enacted by the
Nebraska Legislature. Last verified July 22, 2026. ·
Official source
Also known as: nebraska oral contract statute of limitationsfour year deadline unwritten agreementstatutory liability limitation period nebraskaimplied contract lawsuit deadline nebraskaverbal agreement breach time limit