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.

DeadlinePeriodCPLR ruleNotes
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.

Calculate the deadline from your date

Enter the date of decision, verdict, or discharge of jury and how the paper was served. The result cites the rule and rolls weekends and NY court holidays forward.

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.

DeadlinePersonal deliveryBy 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?
15 calendar days after decision, verdict, or discharge of jury, under CPLR 4405. Within 15 days after decision, verdict, or discharge of the jury. If the paper was served by mail, add 5 calendar days (CPLR 2103(b)(2)); by overnight courier, add 1 business day; by NYSCEF e-service, add 2 days (Uniform Rule 202.5-b(f)(2)). A deadline that lands on a weekend or New York court holiday rolls to the next business day.
What if the deadline falls on a weekend or holiday?
It rolls forward to the next business day under CPLR 2103(a) and General Construction Law §25-a. The calculator applies the roll automatically and flags the affected row.
Can the court extend this deadline?
Usually. CPLR 2004 lets a court extend most statutory deadlines on good cause shown, but an extension is discretionary and should never be assumed before it is granted. Individual part rules may also shorten the default period.

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.

Disclaimer: This tool is for informational purposes only and does not constitute legal advice. This site is not affiliated with the New York State Unified Court System. Verify all deadlines with the applicable CPLR provisions and consult qualified legal counsel.