son has
been in possession under a recorded deed continuously for 20 years, and
had paid taxes thereon during the same, the former owner in that
interval paying nothing, no action to recover such land shall be
entertained unless commenced within 20 years, or before the expiration
of five years following enactment of said provision.[778] Similarly, an
amendment to a workmen's compensation act, limiting to three years the
time within which a case may be reopened for readjustment of
compensation on account of aggravation of a disability, does not deny
due process to one who sustained his injury at a time when the statute
contained no limitation. A limitation is deemed to affect the remedy
only, and the period of its operation in this instance was viewed as
neither arbitrary nor oppressive.[779]
Moreover, as long as no agreement of the parties is violated, a State
may extend as well as shorten the time in which suits may be brought in
its courts and may even entirely remove a statutory bar to the
commencement of litigation. As applied to actions for personal debts, a
repeal or extension of a statute of limitations effects no
unconstitutional deprivation of property of a debtor-defendant in whose
favor such statute had already become a defense. "A right to defeat a
just debt by the statute of limitation * * * [not being] a vested
right," such as is protected by the Constitution, accordingly no offense
against the Fourteenth Amendment is committed by revival, through an
extension or repeal, of an action on an implied obligation to pay a
child for the use of her property,[780] or a suit to recover the
purchase price of securities sold in violation of a Blue Sky Law,[781]
or a right of an employee to seek, on account of the aggravation of a
former injury, an additional award out of a State administered
fund.[782] However, as respects suits to recover real and personal
property, when the right of action has been barred by a statute of
limitations and title as well as real ownership have become vested in
the defendant, any later act removing or repealing the bar would be void
as attempting an arbitrary transfer of title.[783] Also unconstitutional
is the application of a local statute of limitation declaring invalid
any contractual limitation of the right to sue to a period shorter than
two years to an insurance contract made and to be performed outside the
forum State and containing a stipulation that suit thereon must be
brou
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