I agree with Justice CORRIGAN’S opinion, which would affirm the Court of Appeals on the partition issue. I agree that title vested in the surviving joint tenant on the decedent’s death because the mere filing of a partition action does not sever a joint tenancy when no order granting partition was entered before the death. However, I would reverse the judgment of the Court of Appeals on the statute of limitations issue. I disagree that the statute of limitations does not bar recovery on any of the loans. Instead, I would hold that the statute of limitations bars recovery on all but the last loan made because it is the only one to fall within the six-year limitations period. MCL 600.5807(8).

Plaintiff filed this action, claiming that she gave defendant’s decedent a series of checks as loans totaling more than $50,000, for which the parties did not have written contracts. Rather, defendant’s decedent allegedly asked to borrow money at various times over a period of years. Defendant moved for summary disposition, arguing that the statute of limitations barred the claim, and the trial court denied the motion. A jury found that all the checks were loans, all but one of which had not been repaid. The Court of Appeals upheld the denial of summary disposition on the statute of limitations issue, Jackson v Green Estate, unpublished opinion per curiam, issued April 1, 2008 (Docket No. 269244),1 and this Court granted leave to appeal, 482 Mich 981 (2008).

I would hold that the period of limitations expired for all but the last loan. The Court of Appeals correctly observed that if no time is set for the repayment of *222borrowed money, the loan is impliedly payable on demand. See Colburn v First Baptist Church & Society of Monroe, 60 Mich 198; 26 NW 878 (1886).2 But when does the period of limitations begin to run on a loan that is payable on demand? Does it begin running when the loan is made, when payment is demanded, or at some other time? This Court answered that question in Palmer v Palmer, 36 Mich 487, 491 (1877):

It is now well settled that a note payable on demand is payable at once and without demand, so that the statute runs from its delivery. And this rule has been applied where from the form of the contract it is manifest that immediate payment was not expected.

Palmer proceeded to explain the rationale for this rule:

For if the debt did not become payable until fixed by demand, and the demand was optional with the creditor, no tender could be made which would bind him, and he could keep the debt alive in spite of the debtor, for an indefinite period. If there was any infirmity in the consideration, or *223any defect in the binding character of the obligation, he might retain it until all testimony was lost, and defeat the defense. This is the mischief which the statutes of limitation were intended to remedy ....

We cannot but think this to be sound doctrine; whatever may have been the ancient prejudice against statutes of limitation they are now regarded as just and entitled to be fairly construed. If a creditor has the means at all times of making his cause of action perfect, it would be unjust and oppressive to hold that he could postpone indefinitely the time for enforcing his claim by failing to present it. He is really and in fact able at any time to bring an action, when he can by his own act fix the time of payment. It is no stretch of language to hold that a cause of action accrues for the purpose of setting the statute in motion as .soon as the creditor by his own act, and in spite of the debtor, can make the demand payable. It may be otherwise, possibly, where delay is contemplated by the express terms of the contract, and where a speedy demand would manifestly violate its intent.[3] But where no delay is contemplated the *225rule is just and reasonable; and the presentment should be reasonably prompt, or the creditor should be subjected to the operation of the statute. [Id. at 491, 494.]

Palmer was followed in later cases. See, e.g., Beardsley v Webber, 104 Mich 88, 89; 62 NW 173 (1895) (“No demand is necessary on a demand note . . . .”); Citizens’ Savings Bank v Vaughan, 115 Mich 156, 159; 73 NW 143 (1897) (“[T]he universal rule is that [a demand] note is due at once, and that no demand is necessary before bringing suit.”); Peninsular Savings Bank v Hosie, 112 Mich 351, 355; 70 NW 890 (1897) (“ ‘If the instrument be payable on demand, the statute begins to run immediately.’ ”) (citation omitted); Taylor v Rugenstein, 245 Mich 152, 154; 222 NW 107 (1928) (“The general rule is that suit may be brought on a demand note immediately after delivery, and therefore the statute of limitations begins to run from the day of delivery.”).

In light of these authorities, the Court of Appeals erred, in my judgment, when it stated that “the statute of limitations would not begin to run on such a claim until a demand for repayment was made----” Jackson, unpub op at 5 4 Palmer and its progeny established that the period of limitations begins to run *226from the day that a demand note is delivered, unless a contrary intention is apparent. While those cases addressed written demand notes, there is no apparent reason why Palmer should not equally apply to an oral contract.5 In fact, the policies underlying statutes of limitations are implicated even more strongly in the *227latter circumstances because it is more difficult to produce evidence to defend against a stale claim of an oral agreement.6

Thus, I would reverse the Court of Appeals on this issue and hold that all the alleged loans other than the last one fall outside the period of limitations. That is, because plaintiff waited more than six years to demand payment on all the loans but one, all her claims but one are barred by the statute of limitations.

I disagree with the separate opinions of Justices Corrigan, Young, and Markman. On the partition issue, I would allow the merits of defendant’s partition action to be heard because it comes within the purview of the survival statute. See MCL 600.2921. Regarding the statute of limitations issue, I find Smith v Smith Estate, 91 Mich 7; 51 NW 694 (1892), to be controlling, and I would apply its rule here to hold that *228all the claims were timely made except those that related to the first two loans. Accordingly, I would reverse the judgment of the Court of Appeals on both issues.

I. PARTITION

In Michigan, there are two forms of joint tenancies. Albro v Allen, 434 Mich 271, 274; 454 NW2d 85 (1990). The first is the standard form in which, upon the death of a joint tenant, the entire estate transfers to the surviving joint tenant or tenants. Id. at 274-275. In the standard joint tenancy, one joint tenant can unilaterally destroy the right of survivorship by severing the joint tenancy. Id. One way to sever the joint tenancy is a partition action. Smith v Smith, 290 Mich 143, 155; 287 NW 411 (1939), quoting Midgley v Walker, 101 Mich 583, 584; 60 NW 296 (1894).

The second form of joint tenancy is one that has “express words of survivorship in the granting instrument in addition to those creating a joint tenancy, such as . . . ‘with full rights of survivorship.’ ” Albro, 434 Mich at 275 (citation omitted). In contrast to the standard joint tenancy, it is well settled in Michigan that the survivorship quality of this type of joint tenancy cannot be unilaterally severed by the act of one cotenant. Id. at 275-276. Thus, the survivorship right of this type of joint tenancy is indestructible and is not affected by a partition action.

The deeds in this case created both forms of joint tenancies. The September 1991 deed created the second, indestructible variety; thus, the defendant’s partition action had no effect on the joint tenancy’s survivorship quality, and the land automatically transferred to plaintiff upon defendant’s death. The May 1991 deed, however, created a standard joint tenancy, which there*229fore could be affected by a partition action. Thus, the issue in this case is what effect defendant’s death had on his pending partition action regarding the property covered by the May 1991 deed.

This Court’s pronouncements regarding the absolute right of a cotenant to partition, coupled with the plain language of Michigan’s survival statute, MCL 600.2921, demand that defendant’s death not abate his partition action. Partition actions are governed by two sections of the Revised Judicature Act: MCL 600.3304 and MCL 600.3308. MCL 600.3304 states that “[a]ll persons holding lands as joint tenants. . . may have those lands partitioned.” In addition, MCL 600.3308 states that “[a]ny person who has an estate in possession in the lands of which partition is sought may maintain a claim for partition of those lands .. . .” This Court has made strong statements about facially valid partition actions and the right of a joint tenant to compel partition in a standard joint tenancy: “The right of a cotenant to partition is absolute, not a mere matter of grace, within the discretion of the court, regardless of the motives of the parties entitled to partition.” Henkel v Henkel, 282 Mich 473, 482; 276 NW 522 (1937) (quotation marks and citations omitted; emphasis added). Moreover, partition is mandatory “unless there is some paramount or controlling equity which warrants the court in refusing to act....” Id.

When interpreting a statute, the primary goal is to give effect to the intent of the Legislature. Frankenmuth Mut Ins Co v Marlette Homes, Inc, 456 Mich 511, 515; 573 NW2d 611 (1998). When the language of the “statute is clear and unambiguous, judicial construction is precluded.” Id. (quotation marks and citation omitted).

Michigan’s survival statute provides:

*230All actions and claims survive death. Actions on claims for injuries which result in death shall not be prosecuted after the death of the injured person except pursuant to the next section. If an action is pending at the time of death the claims may be amended to bring it under the next section. A failure to so amend will amount to a waiver of the claim for additional damages resulting from death. [MCL 600.2921 (emphasis added).]

The plain language of the statute is clear and unambiguous and therefore in need of no interpretation — all actions survive a claimant’s death.

Not only is this interpretation consistent with the plain language of the statute, it is also consistent with the legislative history of the statute. This Court examined the lengthy history of the survival statute in Hardy v Maxheimer, 429 Mich 422; 416 NW2d 299 (1987). “ ‘Early in its histoxy Michigan adopted a rather liberal “survival act” to preserve causes of action which, under common law, were terminated by the death either of the person injured or the tortfeasor.’ ” Id. at 436, quoting Hawkins v Regional Med Laboratories, PC, 415 Mich 420, 428-429; 329 NW2d 729 (1982). The statute was later amended to “expand[] the number of causes of action which survived a claimant’s death,” but “in [the Revised Judicature Act], the Legislature abandoned its restrictive ‘laundry list’ approach to the survival act” and amended it to its present form. Hardy, 429 Mich at 437. This Court then emphasized that the bill analysis accompanying the act clearly showed the Legislature’s intent. Id. The relevant portions quoted were as follows:

“This section drastically changes the present law .... At common law, personal rights of action died with the person. This seemed manifestly unfair in certain cases, so Survival Acts were written to allow certain actions to survive. There is no good reason for allowing some actions to survive, and not others, apart from cultural inertia....

*231“This section is a logical advance in the legislation in this area. That it has not been made earlier may be due to the unfortunate approach of the statutes in listing those actions which do survive, and thus overlooking those which the statute failed to cover. This section has the added advantage of simplicity in application.” [Id. at 437-438.]

While the survival statute is commonly applied to tort actions, the history of and comments on the statute clearly illustrate the Legislature’s intent to make all claims immune from attacks based on a claimant’s death. The statute clearly abrogates the harsh common-law rule that pending actions die with the death of a party.1 In fact, after reviewing the history of and comments on the statute in Hardy, this Court described the language of the statute as “sweeping and unambiguous” and declared that the statute is “universally applicable to all actions and claims which arise under the Revised Judicature Act.” Id. at 438. A partition action is one of the actions included in the Revised Judicature Act. Given the survival statute’s unqualified language and this Court’s prior examination of the statute, I would hold that because defendant was alive when he filed his action for partition, the action survives and should be heard on its merits. To hold otherwise would frustrate the clear intent of the Legislature and would be inconsistent with this Court’s prior declarations regarding the applicability of the survival statute to actions arising under the Revised Judicature Act.2

*232Moreover, partition actions are equitable in nature. MCL 600.3301. Thus, this Court has broader authority to inject fairness and render a fair judgment. Brown v Fletcher’s Estate, 146 Mich 401, 417-420; 109 NW 686 (1906) (acknowledging a softening of the common-law rule of abatement for a deceased party’s claim when the claim is based in equity). In this case, notions of equity strongly support allowing the merits of defendant’s partition action to be heard. After defendant filed an action for partition, his case sat idle for more than a year while plaintiff appealed the trial court’s earlier ruling regarding the validity of the deeds. Eventually, the Court of Appeals summarily and correctly affirmed the validity of the deeds. Nonetheless, the Court of Appeals, without citing any supporting authority, held that because defendant had died before an order of partition was entered, his claim was moot. Given the validity of the May 1991 deed and defendant’s absolute right to partition, I would allow defendant’s action to continue. But for plaintiffs lengthy, unmeritorious, and collateral appeal and defendant’s untimely death, the merits of defendant’s claim would certainly have been heard. To hold otherwise would not only ignore notions of equity and this Court’s pronouncements that the right to partition is absolute, but would also frustrate our Legislature’s intent to make claims that arise under the Revised Judicature Act immune from attacks based on a claimant’s subsequent death. See Hardy, 429 Mich at 436-438.3

*233II. STATUTE OF LIMITATIONS

“[T]he period of limitations runs from the time the claim accrues,” which occurs “at the time the wrong upon which the claim is based was done . ..MCL 600.5827.4 In contract claims,, the time of the wrong is the moment that the contract is breached. AFSCME v Highland Park Bd of Ed, 457 Mich 74, 90; 577 NW2d 79 (1998) (opinion by CAVANAGH, J.). This case involves oral loans with no terms expressing a time for repayment. Repayment of this type of loan is due upon a demand. Colburn v First Baptist Church & Society of Monroe, 60 Mich 198, 200; 26 NW 878 (1886). Hence, a claim for nonpayment of such a loan accrues when a demand for repayment is made. However, this Court has held that accrual cannot be left to the whim of the lender because, if it were, the lender could wait in near perpetuity until demanding payment, which would contravene the venerable aims of statutes of limitations. Indeed, in Smith Estate, 91 Mich at 11, this Court held that if a demand is necessary for accrual of the claim, it should be made within a reasonable time, and if the demand is not made within a reasonable time, then accrual occurs and the period of limitations begins to run at the end of the period that would have been a reasonable time in which to make the demand.

*234In Smith Estate, the plaintiff sued to enforce a claim for the value of logs that were loaned to the defendant after the defendant failed to either return the logs or pay the plaintiff their value. Id. at 8-11. The Court, after reviewing testimony regarding the terms of the oral contract, held that the transaction was a sale and the claim was barred by the statute of limitations because the plaintiff failed to bring suit within six years after a reasonable time to demand payment had passed. Id. at 11-12.5 The Court held that if a plaintiff failed to make a demand for repayment within a reasonable time, we should presume that a demand was made at the expiration of the reasonable time to begin the running of the period of limitations. The Court defined a reasonable time as equivalent to the six-year period of limitations for an ordinary money claim, thus giving a party six years to make a demand and six years to bring suit after having made the demand. Id. The Court adopted this rule from Keithler v Foster, 22 Ohio St 27 (1871). Smith Estate, 91 Mich at 12.6 Moreover, the Court reasoned that its rule was driven by the purpose of the statute of limitations: “The object of the statute of limitations is a beneficial one; and it is a salutary protection against fraudulent and stale claims, which without it might purposely be postponed for enforcement until the lapse of time had destroyed the proofs of their falsity.” Id. at 11.

*235In essence, Smith Estate gives a plaintiff 12 years to bring a contract action on an oral loan that specified no time for repayment. The plaintiff has a reasonable time in which to make a demand, which Smith Estate held is six years as a matter of law. If no demand is made within six years, then the court will “presume” that a demand was made for the purposes of the statute of limitations.7 Then, under the statute of limitations, the plaintiff has six years from the date of this presumed demand to bring a claim.8

In this case, consistently with the rule of Smith Estate, I would hold that the July 1991 and September 1992 oral loans between plaintiff and defendant are barred by the statute of limitations. Because plaintiff failed to make a demand for repayment within a reasonable time, I would presume that a demand was made at the expiration of the reasonable time and thus measure the period of limitations from the date of the presumed demand. There were 11 oral loans, which were made between July 1991 and February 1999. Plaintiff made no demand for payment until she filed her complaint covering all these loans in November 2004. Thus, for any loan made more than 12 years *236earlier, i.e., before November 1992, plaintiffs claim would be untimely.9 Plaintiffs claims included two such loans, which originated in July 1991 and September 1992. Thus, her claims on those loans were barred by the statute of limitations in July 2003 and September 2004. In contrast, the claims relating to the remaining nine loans, which were made between March 1994 and February 1999, were timely under the November 2004 complaint.10

*237As noted, I agree with Justice Young’s statement that “the absence of a specific time for repayment does not allow a creditor to withhold this demand for an indefinite period of time.” Ante at 217. However, I do not agree with the construct that Justice YOUNG develops to address this concern. He institutes a rule that allows the jury to decide when a presumed demand should occur, which is set at what the jury determines to be a reasonable time. Justice YOUNG bases this construct on the idea “that the parties intended plaintiffs demand for repayment to occur within a reasonable amount of time.” Ante at 217. I decline to accept this construct for several reasons.

First, there is little precedential support for this construct. Justice YOUNG relies on Pierson v Davidson, 252 Mich 319; 233 NW 329 (1930), to support his construct. But Pierson is both factually and legally distinguishable from the present case. Factually, Pier-son involved a written oil and gas lease agreement. Id. at 320-321. Thus, unlike the present case, Pierson did not deal with an oral loan. And legally, Pierson dealt with the contractual requirement that the lessor clear a cloud on the title to the real property or the lease would “ 'be voided and extinguished, and shall become null and void ....’” Id. at 321. Pierson did not deal with the question of when payment on an oral promise to repay, which hinges on a demand, was due. In contrast, Smith Estate dealt with this Court’s unanimous statement that, in the case of an oral loan with no time set for repayment, a demand is to be presumed six years from the loan’s inception and accrual occurs at that time. In light of Justice YOUNG’s refusal to rely on Smith Estate *238(a case that is factually and legally exactly on point), I question his reliance on Pierson because that case seems much less applicable here than Smith Estate. It is unclear why Justice YOUNG finds Smith Estate too dissimilar for application here, while concomitantly finding the much more distinguishable Pierson case to be controlling.

Second, I believe that Justice Young’s construct overly diminishes the statute of limitations. Justice YOUNG puts no restriction on how long a reasonable amount of time may extend. Instead, he would allow a reasonable amount of time to go on indefinitely. I think that this eviscerates the statute of limitations and undermines its purposes in this context, as Smith Estate clearly discussed. See Smith Estate, 91 Mich at 11-12. In contrast to Justice Young’s construct, the Smith Estate construct presents a better balance between the rationales supporting the statute of limitations and the legal precepts pertaining to oral contracts. The Smith Estate construct gives definite answers. Under no circumstances may a plaintiff carry out his claim more than 12 years past the time of the oral loan that has no time set for repayment. As noted, this Court lauded the stability and predictability of this construct in Smith Estate because it reduces fraud and the litigation of stale issues. See id. at 11. Justice Young’s construct does not protect against these problems. The Smith Estate construct also honors the concepts that an oral loan is not due until a demand is made and a claim does not accrue until a demand (presumed or actual) occurs. In contrast, under Justice Young’s construct, a plaintiff need only convince a jury that it was reasonable to delay the demand for payment for any number of years in order to bring claims on loans that originated, conceivably, decades in the past.

*239Both Justice YOUNG’s construct and the Smith Estate construct presume a demand at some point after the oral loan was made. I find the Smith Estate construct’s method of determining when that presumption occurs to be more closely tied to the purposes of the limitations period, while honoring basic contract tenets. Further, Smith Estate provides the most applicable standard for the facts and issues in the present case; therefore, I would apply it in place of Justice YOUNG’s construct. Under the Smith Estate construct, I would hold that only the claims on the first two loans (those arising before 1992) were time-barred.

I note that Justice MARKMAN questions my reliance on Smith Estate. He argues that the contract in Smith Estate contemplated a delay in repayment, whereas the “express terms of the instant contracts” did not contemplate any such delay. Ante at 223 n 3. I respectfully disagree. I question whether Justice MARKMAN can opine on the “express terms” of the instant contract with any specificity, given that the parties litigated the very existence of any oral contract. Indeed, the trial court discussed this case’s facts as follows when reviewing a motion for summary disposition:

The loans — or the distribution of money... is a close question, but there is some testimony that [Green] made a request to borrow, which I think impliedly includes a promise to repay, and while [Jackson] said [in her deposition] there was no specific agreement or promise to repay ... , which certainly hurts her case, she did say that there was a request to borrow and, therefore, that’s what caused the advance of monies.

So I think that there is a factual question as to whether these advances were gifts, whether they were, in fact, loans, as [Jackson] now claims, or whether they were, in fact, compensation as [Green] claims at least part of the advances were for.

*240Thus, while the jury eventually decided that there were enforceable oral contracts, I do not believe that the facts of this case support Justice MARKMAN’s assertion that the contracts’ express terms did not contemplate a delay in repayment.11 The record only supports the fact that defendant asked to borrow money from plaintiff and that plaintiff responded by writing numerous checks. Moreover, the parties’ actions actually indicated that they did contemplate a delay in repayment because plaintiff continually made numerous loans to defendant over a term of years. It strains reason to conclude, as Justice MARKMAN does, that the parties expected payment immediately yet, despite never receiving any such immediate payment, plaintiff continued to make additional loans over several years.12

*241Justice MARKMAN also argues that Smith Estate limited its holding to cases in which a demand is necessary. Assuming that he is correct, I do not see how this precludes the application of Smith Estate in this case. As Justice MARKMAN notes, if “no time is set for the repayment of borrowed money, the loan is impliedly payable on demand.” Ante at 221-222, citing Colburn. It is uncontested that this case involves loans that set no time for repayment of the borrowed money. Hence, I think Smith Estate applies.

Justice MARKMAN also suggests that applying Smith Estate here “anomalously provide[s] those parties who never make a timely demand with a longer period in which to bring an action than those parties who do make a timely demand.” Ante at 224 n 3.1 disagree that following Smith Estate's general rule that a demand is necessary to trigger accrual causes anomalous results. Under Smith Estate, the period in which to bring a *242claim is always six years — after accrual of the claim. Justice MARKMAN and I simply disagree on when accrual should occur. His insistence (contrary to the general rule) that accrual must occur at the loan’s inception is what causes his perception of anomalous results. Under Smith Estate, every claimant has six years to bring his claim after it accrues, which is triggered by a demand or the presumed demand, whichever happens first. While I accept that Justice MARKMAN disagrees with this legal construct, I disagree with his assertion that it causes anomalous results, especially in light of his counterintuitive position that parties make oral loans to each other and expect payment immediately.13

*243Finally, Justice MARKMAN adopts his immediate-accrual construct by incorporating the holding from Palmer v Palmer, 36 Mich 487 (1877). While conceding that Palmer and its progeny “addressed written demand notes,” Justice MARKMAN concludes that “there is no apparent reason why Palmer should not equally apply to an oral contract.” Ante at 226. I respectfully note several reasons why Palmer should not apply to oral contracts like those in this case.

Palmer, a case concerning a promissory note, held that “a note payable on demand is payable at once and without demand, so that the statute [of limitations] runs from its delivery.” Palmer, 36 Mich at 491 (emphasis added). This Court has defined a promissory note as “a written unconditional promise by one person to pay to another person therein named... a fixed sum of money . . . .” Parker v Baldwin, 216 Mich 472, 474; 185 NW 746 (1921) (emphasis added). Further, “[n]o contract or agreement is a promissory note which does not provide for the payment of money, absolutely and unconditionally.” Id. (emphasis added). Thus, a promissory note is more than a contract to repay a loan: it is a written instrument that embodies a formal promise to repay. See MCL 440.9102(l)(uu) and (mmm); MCL 440.3104. The case at hand, however, involves informal oral contracts, which do not meet the strict formalities of a promissory note. Therefore, in determining when the period of limitations begins to run on an oral contract that does not specify the terms for repayment, this Court should apply caselaw dealing with general *244breach of contract actions, such as Smith Estate, rather than those cases that deal with the hypertechnical code of negotiable instruments.

In addition, the only justification that Justice MARKMAN gives for applying Palmer is that doing so is supported by the policies that underlie the statute of limitations. While I agree with Justice MARKMAN that those policies are strongly implicated when dealing with an oral agreement, Smith Estate properly addressed this issue without subjecting informal oral agreements to the more stringent rules regarding promissory notes. See Smith Estate, 91 Mich at 11-12.

Also, unlike the parties in Palmer, the parties here did not formulate a written unconditional promise to repay within 30 days after demand. See Palmer, 36 Mich at 490. In contrast, here there were merely oral requests to borrow money, which prompted plaintiff to write 11 checks over a span of several years. Wfiiile plaintiff expected that she would be repaid, there were no specific agreements about repayment or promises to repay the borrowed funds. Thus, as noted, in contrast to Justice MARKMAN’s assertion, there were no “express terms” of the contracts that contemplated immediate payment.

Finally, applying Palmer’s view that the period of limitations begins to run on the date of delivery, and therefore no demand is necessary, is inconsistent with this Court’s declarations regarding basic contract principles. In essence, Palmer puts the oral-contract borrower in immediate breach of the contract and thus makes a loan that had no specified time set for repayment due immediately. This conflicts with our pronouncement that “when a contract is silent as to time of performance or payment, absent any expression of a contrary intent, the law will presume a reasonable time.” Duke v Miller, 355 Mich 540, 543; 94 NW2d 819 *245(1959). Moreover, application of Palmer here contravenes common sense: informal oral loans are handshake agreements that intuitively are not breached at the time of the handshake. It would be nonsensical to assume that informal loans that consisted of thousands of dollars would be due immediately, as they would be under Palmer. My application of Smith Estate does not subject informal oral handshake-type agreements to the strict formalities of promissory notes, and it is consistent with this Court’s pronouncements regarding basic contract principles.

In sum, Justice MARKMAN’s construct represents one end of the spectrum on this issue. He would have accrual occur at the inception of the loan, which I think would prematurely trigger the running of the period of limitations because it contradicts both the facts of this case and this Court’s general pronouncements on oral contracts. In essence, Justice MARKMAN gives the interests supporting the statute of limitations too much weight. Justice YOUNG, in contrast, represents the other end of the spectrum. Under his construct, the purposes of the statute of limitations are given too little respect because a claimant can extend the accrual of his claim indefinitely. I recognize that both constructs represent good-faith attempts to balance the tenets of statutes of limitations with the countervailing principles of contract law. However, I find them both to be out of balance. I think that applying Smith Estate to this issue achieves the best balance between the concern of ensuring that contracts will be enforced and the competing concern that claims will not become stale.

III. CONCLUSION

For all these reasons, I would reverse the judgment of the Court of Appeals on both issues.

I believe that leave to appeal was improvidently granted in this case because the result reached by the Court of Appeals in this case is correct.

I agree with the analysis set forth in Justice CORRIGAN’s opinion, which affirms the Court of Appeals on the partition issue. I would further hold that the statute of limitations does not bar plaintiffs claim for breach of contract on the series of oral agreements for loans. Because the loans were made with no fixed time of repayment, they were payable on demand. The period of limitations would not begin to run on such a claim until either a demand was made, expressly or by filing a complaint, or a reasonable amount of time had elapsed without a demand. In this case, no demand was made until the action was filed.

*216The issue of when a period of limitations begins to run on an oral agreement for a loan that has no fixed date of payment is a question of law that we review de novo. Collins v Comerica Bank, 468 Mich 628, 631; 664 NW2d 713 (2003).

The applicable limitations period for plaintiffs breach of contract claim is six years. MCL 600.5807(8). The central issue here is when the limitations period began to run. “Except as otherwise expressly provided, the period of limitations runs from the time the claim accrues.” MCL 600.5827. Moreover, a claim generally accrues when the wrong is done. Boyle v Gen Motors Corp, 468 Mich 226, 231; 661 NW2d 557 (2003).

The general rule governing the commencement of the running of the statute of limitations is that the statutory-period is computed from the time when the right of action that the plaintiff seeks to enforce first accrued; ordinarily, in an action based on a contract, accrual occurs as soon as there is a breach of contract, with some courts qualifying this by stating that accrual occurs when the promisee discovers or should have discovered the breach, and others stating that accrual occurs upon breach, whether or not the promisee is then aware of the breach. [31 Williston, Contracts (4th ed), § 79:14, pp 303-307 (emphasis added).]

In determining when the period of limitations begins to run on a loan that has no repayment term, we must therefore necessarily determine when a breach of contract occurs.

The oral loan agreements in this case did not set a time for repayment. There is no controlling caselaw that establishes when a borrower is in breach of an oral loan agreement that is silent concerning when repayment must occur. Thus, this Court should articulate a rule of law to determine when a breach occurs under the circumstances in this case.

*217We do have some established bedrock principles to guide us in formulating such a rule. A loan made with no fixed time of repayment is payable on demand. Colburn v First Baptist Church & Society of Monroe, 60 Mich 198, 200; 26 NW 878 (1886). As a general matter, because no terms of repayment were specified in the contracts, the oral loan agreements could not have been breached until payment was demanded and the demand was rebuffed.

Nevertheless, the absence of a specific time for repayment does not allow a creditor to withhold this demand for an indefinite period of time. In the absence of an agreement to the contrary, we presume that the parties intended plaintiffs demand for repayment to occur within a reasonable amount of time. See Duke v Miller, 355 Mich 540, 542-543; 94 NW2d 819 (1959) (“[W]hen a contract is silent as to time of performance or payment, absent any expression of a contrary intent, the law will presume a reasonable time.”); Pierson v Davidson, 252 Mich 319, 324; 233 NW 329 (1930) (“It is a general rule of law that where no time is stipulated, a reasonable time will be presumed. Reasonable time depends upon the facts and circumstances of each case.”).1 Determining what constitutes a reasonable amount of time to request repayment of a loan is necessarily a factual question properly decided by the jury.

Ultimately, a breach is the sine qua non of any contract dispute regarding repayment. Justices Markman and CAVANAGH provide alternative theories of when a breach *218occurs if the parties failed to supply a repayment term. Justice MARKMAN determines that a breach occurs immediately on payment of the loan principal. Justice CAVANAGH determines that a breach occurs exactly six years after payment of the loan principal. Neither theory comports with the practice of parties, especially in a case like this, which involved a series of loans made over a period of eight years.

Justice MARKMAN would extend the rule articulated in Palmer v Palmer, 36 Mich 487 (1877). In Palmer, this Court held that “a note payable on demand is payable at once and without demand, so that the statute runs from its delivery.” Id. at 491. The central rationale of the Palmer rule was to prevent a creditor from keeping a debt alive by declining to make a demand until evidence grew stale, thereby defeating the statute of limitations. “If a creditor has the means at all times of making his cause of action perfect, it would be unjust and oppressive to hold that he could postpone indefinitely the time for enforcing his claim by failing to present it.” Id. at 494.2

Palmer and its progeny thus recognized an implied demand for repayment of written demand notes. This Court has not applied the Palmer holding to oral loan agreements. I can discern no reason to extend what is essentially a legal fiction — that a breach occurs immediately upon the making of a loan even though no actual demand was made — to oral loan agreements.

I believe that the principle of law articulated in Palmer, which presumes a demand for repayment — and *219therefore a breach — immediately upon payment of the loan principal, is illogical and entirely inconsistent with contracting parties’ intent. I suspect that no one making or receiving a loan believes that the recipient is automatically in breach of the loan as soon as the principal is paid. However, this is the “logic” of the Palmer rule. For this reason, I would not extend Palmer beyond its facts.

Justice CAVANAGH would extend the mechanical rule established in Smith v Smith Estate, 91 Mich 7; 51 NW 694 (1892), to bar recovery on any loan made more than 12 years before the plaintiff filed her complaint. Smith concluded that, when no express demand for payment has been made, “a demand should be presumed at the expiration of the time when an ordinary money claim would be barred by the statute [of limitations],” id. at 11, that is, six years. A breach would then automatically occur after six years, and the creditor would then have an additional six years to bring a cause of action for payment. In this respect, Smith suffers from the same wooden approach as Palmer in determining when a breach of a contract occurs if the parties have not supplied a term for repayment. Why, given all the variables in a contractual relationship, is six years ineluctably a “reasonable” time in which to make a demand? In this very case, the lender continued to make a series of new loans — a fact that would seem to undermine either the Palmer “breach on payment of the loan” or the Smith “six years equals a breach” theory.

Smith is distinguishable from the instant case because it involved not a monetary loan, but a sale of logs. “[W]e have no doubt that the transaction was a sale. . ..” Id. Although the Smith Court would have applied this rule to loans, see id. at 12, that discussion *220was dictum. I would not extend this strict rule to the context of a loan, as the rule fails to take into account the particular circumstances of a given loan. Instead, I would leave the question whether a plaintiff waited an unreasonable amount of time before demanding repayment to the wisdom of a jury.

Plaintiff here did not demand repayment until filing this action. In the absence of a demand for repayment, defendant could not have breached the loan agreements until a reasonable time in which to have made a demand had elapsed.3 Any breach of contract claim would need to have been filed within six years of that time because the limitations period would not have begun to run until that time. I agree with the Court of Appeals that “it was not error for the [circuit] court to determine that the nature of the disbursements, and consequently whether plaintiffs claims regarding the alleged loans were barred by the applicable statute of limitations, was a question of fact that was properly decided by a jury.”

In conclusion, I would hold that the statute of limitations did not bar plaintiffs breach of contract claim because plaintiff did not make a demand for repayment until she filed this lawsuit and no breach of contract could have occurred unless and until a demand was made and refused or a reasonable amount of time had elapsed without a demand. I agree with the Court of Appeals that the finder of fact properly decided this case.

We granted leave to appeal to consider whether an action to partition real estate may go forward when the joint tenant who filed the action died before an order of partition entered.1 We would hold that title vested in the surviving joint tenant on the decedent’s death because the mere filing of a partition action does not sever a joint tenancy and no order granting partition was entered before the death. We would thus affirm the trial court’s denial of defendant’s motion for summary disposition and the judgment of the Court of Appeals on the partition issue.

I. PACTS AND PROCEEDINGS

At issue in this case are two parcels of real estate held by plaintiff and defendant as joint tenants and a series *212of oral loans from plaintiff to defendant.2 In May 1991, defendant negotiated the purchase of a parcel of land on behalf of plaintiff, and the deed conveyed the land to both parties as joint tenants. In September 1991, plaintiff purchased a second parcel of property, which was conveyed to plaintiff and defendant as joint tenants with full rights of survivorship.

In 2004, plaintiff filed a breach of contract action, alleging that defendant had failed to repay the loans. Plaintiff also sought to force defendant to relinquish his right to the two parcels of land. The trial court granted summary disposition for defendant regarding the deeds for the properties, holding that the deeds were properly executed and gave defendant valid property interests. Regarding the loans, the court did not accept defendant’s argument that the statute of limitations barred plaintiffs claim. A jury found that each check plaintiff issued to defendant was a loan, and the court entered judgment on the verdict in plaintiffs favor.

Defendant then filed a separate action for partition of the parcels. At plaintiffs request, the partition action was stayed pending the appeal in this case. Defendant unexpectedly died while the appeal was pending in the Court of Appeals. His estate was substituted as the plaintiff in the partition action and as the defendant in this case.

The Court of Appeals affirmed the trial court’s ruling that defendant possessed a valid property interest in the two parcels, but held that because no order severing the joint tenancy had issued in the partition action before defendant died, defendant’s interests in the parcels reverted to plaintiff upon defendant’s death. *213The Court of Appeals further held that the statute of limitations did not bar plaintiffs breach of contract action for repayment of the loans because the claim did not accrue until plaintiff demanded repayment by filing her complaint in 2004.3

We granted defendant’s application for leave to appeal.4

II. STANDARD OF REVIEW

Whether a partition action may go forward if a joint tenant dies before the joint tenancy is severed is a question of law that we review de novo. Cardinal Mooney High School v Michigan High School Athletic Ass’n, 437 Mich 75, 80; 467 NW2d 21 (1991).

III. PARTITION

We agree with the Court of Appeals that defendant’s interest in the parcel of land5 automatically reverted to plaintiff when defendant died. Thus, defendant’s estate has no interest in the property, and even if defendant’s partition action survived his death under Michigan’s survival statute, MCL 600.2921, nothing remains to partition.

“The principal characteristic of the joint tenancy is the right of survivorship. Upon the death of one joint tenant, the surviving tenant or tenants take the whole estate.” Albro v Allen, 434 Mich 271, 274-275; 454 *214NW2d 85 (1990). An ordinary joint tenancy6 may be severed, and the right of survivorship thereby destroyed, by an act of the parties, conveyance by either party, or levy and sale on an execution against one of the parties. Id. at 275.

A party can sever a joint tenancy by compelling a partition. Smith v Smith, 290 Mich 143, 155; 287 NW 411 (1939), quoting Midgley v Walker, 101 Mich 583, 584; 60 NW 296 (1894). Until an order of partition has been entered, however, a partition has not been compelled and, thus, the joint tenancy has not been severed. See Anno: What acts by one or more of joint tenants will sever or terminate the tenancy, 64 ALR2d 918, 956 (explaining that “[i]t is not the filing of the partition action which terminates the joint tenancy, but only the judgment in such action which has that effect”) (quotation marks and citation omitted).

Indeed, the universal rule in the United States is that a pending suit for partition does not survive the death of one of the joint tenants. See Heintz v Hudkins, 824 SW2d 139, 142-143 (Mo App, 1992), and cases cited therein. “This rule is based on two related concepts: First, the theory of survivorship — that at the moment of death, ownership vests exclusively in the surviving joint tenant or tenants — and second, the doctrine that severance of the joint tenancy does not occur until the *215partition suit reaches final judgment.” Id., citing Cobb v Gilmer, US App DC 398, 400; 365 F2d 931 (1966).

Accordingly, we would hold that the filing of the partition action did not sever the joint tenancy because an order effectuating a partition had not entered at the time of defendant’s death. Therefore, regardless of whether defendant’s partition action survived his death under the survival statute, his interest in the parcel of land did not.

IV CONCLUSION

We would hold that defendant’s filing of the partition action did not sever the joint tenancy because no order granting partition was entered before defendant’s death. Thus, title vested in plaintiff when defendant died, and nothing remains to partition. The Court of Appeals correctly analyzed the partition issue, and we would therefore affirm its judgment on that issue.