REYNOLDSVILLE CASKET CO. v. HYDE

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Case Basics
Docket No. 
94-3
Petitioner 
Reynoldsville Casket Co. et al.
Respondent 
Hyde
Advocates
(on behalf of the Petitioners)
(on behalf of the Respondent)
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Facts of the Case 

A collision between a car and a truck occurred in Ohio. More than three years later, Carol Hyde, a passenger in the car, sued the truck driver and his employer for negligence in the Court of Common Pleas. Ohio had a two-year statute of limitations for such actions, but because the truck driver and his employer were from out of state, a special provision tolled the running of the statute of limitations. 10 months after this suit began, the Supreme Court decided in Bendix Autolite Corp. v. Midwesco Enterprises, Inc., 486 U.S. 888 (1988) that the tolling provision placed an unconstitutional burden on interstate commerce. The Court of Common Pleas applied Bendix and dismissed Hyde’s suit as untimely. The appellate court affirmed the dismissal, but the Ohio Supreme Court reversed on the ground that Bendix could not be retroactively applied to claims that commenced prior to that decision.

Question 

Can Ohio apply its unconstitutional tolling provision to claims that accrued prior to Bendix?

Conclusion 
Decision: 9 votes for Reynoldsville Casket Co., 0 vote(s) against
Legal provision: Article 6, Section 2: Supremacy Clause

No. In a unanimous decision, Justice Stephan G. Breyer wrote for the majority, holding that the Bendix rule must be retroactively applied. Hyde conceded that the Supreme Court had already decided in Harper v Virginia Dept. of Taxation, 509 U.S. 86 (1993) that when the court applies a new legal rule courts must treat the new rule as retroactive. The Court rejected Hyde’s claim that applying the rule would unfairly deny her a remedy. Justice Anthony M. Kennedy wrote a special concurrence stating that Bendix did not announce a new rule and merely applied existing precedent. Following this reasoning, the discussion of retroactivity was unnecessary.

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REYNOLDSVILLE CASKET CO. v. HYDE. The Oyez Project at IIT Chicago-Kent College of Law. 12 December 2014. <http://www.oyez.org/cases/1990-1999/1994/1994_94_3>.
REYNOLDSVILLE CASKET CO. v. HYDE, The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/1990-1999/1994/1994_94_3 (last visited December 12, 2014).
"REYNOLDSVILLE CASKET CO. v. HYDE," The Oyez Project at IIT Chicago-Kent College of Law, accessed December 12, 2014, http://www.oyez.org/cases/1990-1999/1994/1994_94_3.