Definition
A Latin phrase meaning "within six years." The phrase was used as a formal pleading term in the Latin-form plea of the statute of limitations, signaling that the cause of action arose within the six-year period prescribed by the applicable limitations statute — and therefore that the action was timely brought.
The phrase functions as a temporal marker embedded in a formulaic pleading, not as a substantive legal rule in itself. The six-year period it references was associated with particular common law actions, especially actions of debt and certain other personal actions, under English limitation statutes including the Statute of Limitations of 1623 (21 Jac. 1, c. 16).
Why It Matters in Research
Researchers encounter this phrase almost exclusively in pre-modern English and early American pleading records, where Latin-form pleadings remained standard. Its appearance signals that a statute of limitations issue is present in the case — either as a defense or, in the affirmative form of the plea, as a declaration that the action is not time-barred.
The key navigational point: infra sex annos is not a rule of limitations law. It is a pleading artifact. Researchers should not treat it as evidence of the applicable limitations period in a given jurisdiction without independently confirming which statute the pleading was invoking. "Six years" was common but not universal; different actions carried different periods, and early American statutes frequently diverged from English predecessors.
Once English and American courts transitioned away from Latin pleading — England via the Hilary Rules (1834) and eventually the Common Law Procedure Act 1852; American jurisdictions through code pleading reforms beginning with New York's Field Code (1848) — the phrase disappeared from active legal use. Corpus materials from after roughly the mid-nineteenth century will not contain it in functional pleadings, though it persists in legal dictionaries, form books, and treatises discussing the history of pleading.
Researchers working in colonial American or early republic case records may find variations in spelling and spacing (infra sexannos, intra sex annos). Confirm the phrase is not a transcription artifact before drawing conclusions.
Historical Dictionary Support
Both editions of Black's Law Dictionary agree on the core meaning — "within six years" — and both locate the phrase in the context of the Latin-form limitation plea. The first edition of Black's is notable for a minor anomaly: the source material provided here reflects "Within six M years," which appears to be a transcription or typographical artifact; the second edition's cleaner rendering ("within six years") is consistent with the phrase's established meaning and historical usage.
Neither edition elaborates on which specific limitation statutes employed this formula, the history of Latin pleading that made such phrases necessary, or the range of actions to which the six-year period applied. Researchers needing that context must go beyond the dictionary entries to pleading treatises such as Chitty's A Treatise on Pleading and Parties to Actions (various editions) or Tidd's The Practice of the Courts of King's Bench and Common Pleas.
Jurisdictional Note
The phrase originated in English common law pleading practice and migrated into early American courts that followed English pleading forms. Its currency varied by jurisdiction and period. Courts that adopted code pleading earlier abandoned Latin pleading forms sooner, making the phrase essentially obsolete in those jurisdictions by the second half of the nineteenth century.