Decision, verdict, or discharge of jury
Triggering event: Decision, verdict, or discharge of jury. Once this happens in a New York civil action, one deadline starts running under the CPLR. The rule is listed below with the governing section. Enter your date to get the exact due date, adjusted for the service method and rolled off weekends and New York court holidays.
| Deadline | Period | CPLR rule | Notes |
|---|---|---|---|
| Post-trial motion (new trial / JNOV) | 15 calendar days after the triggering event | CPLR 4405 ↗ Article 44 — Trial Motions | Within 15 days after decision, verdict, or discharge of the jury. |
Worked example: decision, verdict, or discharge of jury on Tuesday, September 15, 2026
If decision, verdict, or discharge of jury happened today, here is when each deadline would fall depending on how the paper was served. Dates already account for the weekend and holiday roll.
| Deadline | Personal delivery | By mail (+5 days) | NYSCEF e-service (+2 days) |
|---|---|---|---|
| Post-trial motion (new trial / JNOV) | Wednesday, September 30, 2026 | Monday, October 5, 2026 | Friday, October 2, 2026 |
Post-trial motion (new trial / JNOV)
15 calendar days after decision, verdict, or discharge of jury. Within 15 days after decision, verdict, or discharge of the jury. Governing rule: CPLR 4405 (Article 44, Trial Motions).
How the service method changes the date
The period runs from service, and the method of service can extend it. Under CPLR 2103(b), mail adds 5 calendar days, overnight courier adds 1 business day, and NYSCEF e-service adds 2 days under Uniform Rule 202.5-b(f)(2). Personal delivery adds nothing. When the last day falls on a Saturday, Sunday, or New York public holiday, the deadline rolls to the next business day (CPLR 2103(a); General Construction Law §25-a).
Frequently asked questions
How long after decision, verdict, or discharge of jury is the post-trial motion (new trial / jnov) in New York?
What if the deadline falls on a weekend or holiday?
Can the court extend this deadline?
Other deadlines under Article 44 (Trial Motions)
Browse every CPLR deadline by triggering event →
Individual part rules and the Uniform Civil Rules (22 N.Y.C.R.R. Part 202) often impose deadlines shorter than the CPLR default. Check the assigned judge’s part rules before relying on a statutory period.