The Oyez Project: Judicial Power Issues - Untimely Filing Decisions

Board Of Regents v. Tomanio

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Crown Coat Front Co. v. U.S.

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Graham County Water District v. United States

Does the six-year statute of limitations in the False Claims Act apply to suits brought by individuals who were retaliated against by their employers for assisting an investigation of false or fraudulent claims?

No. In a 7-2 decision, the Court ruled that the six-year statute of limitations did not apply to suits for retaliation. The majority opinion by Justice Clarence Thomas found the statute of limitations "ambiguous." The ambiguity arose from the fact that the six-year limitation in the FCA starts from the time the false claim was made. Yet in a retaliation suit, no actual false claim needs to be alleged. The plaintiff only has to allege that her employer retaliated against her in connection with a federal investigation. The Court found that the ambiguity could be resolved by interpreting the statute of limitations to apply only to suits for false claims, not to retaliation suits. The Court left to the lower courts the question of which state statute of limitations should apply in place of the six-year limitation. Justice Stephen Breyer, joined by Justice Ruth Bader Ginsburg, dissented. The dissent characterized the statute of limitations as "unusual" but "reasonably clear," and argued that it should be read to apply to retaliation actions.

Hadley v. Junior College District

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Irwin v. Veterans Administration

Does the 30-day window after "receipt of notice of final action taken" by the EEOC within which a suit against the federal government must be filed begin when an attorney's office receives notification, or when the attorney or client himself receives notification?

The 30-day window begins as soon as either the attorney's office, the attorney, or the client receives notification - whichever comes first. In an opinion written by Chief Justice William H. Rehnquist, the Supreme Court held that lower courts have consistently held that notice to an attorney's office qualifies as notice to the client. "The practical effect of a contrary rule would be to encourage factual disputes about when actual notice was received, and thereby create uncertainty in an area of the law where certainty is much to be desired," wrote Chief Justice Rehnquist.

Johnson v. U.S.

Is the vacating of a state conviction a "fact" as that term is used in the federal law setting out a statute of limitations on federal sentence modification motions, thus commencing the statute's 1-year limitations period?

Yes. In a 5-4 opinion delivered by Justice David H. Souter, the Court that the vacating of a state sentence that underlay a federal sentence enhancement was a "fact" within the meaning of the law, but that fact had to have been discovered with due diligence: that is, the prisoner must have promptly sought to have the state judgment vacated. The Court held that by waiting until more than three years after his federal sentence, Johnson failed to show due diligence in seeking to have his original state convictions vacated.

Jones v. R.R. Donnelley and Sons Co.

Does the United States Code's four-year statute of limitations for suits brought under acts of Congress passed after 1990 apply only to new laws, or does it also apply to amendments of previously existing laws?

It also applies to amendments of previously existing laws. Writing for a unanimous Court, Justice John Paul Stevens stated "[a]n amendment to an existing statute is no less an 'Act of Congress' than a new, stand-alone statute." The four-year statute of limitations therefore applies to any act or amendment to an act passed by Congress after 1990.

Lockhart v. United States

Could the United States offset Social Security benefits to collect a student loan debt that had been outstanding for over 10 years?

Yes. In a unanimous opinion delivered by Justice Sandra Day O'Connor, the Court held that the Debt Collection Improvement Act made Social Security benefits subject to offset and that the Higher Education Technical Amendments removed the 10-year limit that would otherwise bar the offset.

Pace v. DiGuglielmo

If a state court rejected Pace's post-conviction appeal as untimely, could his federal habeas petition still be "properly filed" within the context of the federal law establishing a one-year statute of limitations for such petitions?

No. In a 5-4 opinion delivered by Chief Justice William H. Rehnquist, the Court held that the federal statute of limitations barred Pace's petition, as it was filed beyond the deadline. Pace was not entitled to statutory tolling because a petition filed after a time limit, which does meet any exceptions to that limit, was no more "properly filed" than a petition filed after a time limit permitting no exception. Moreover, because Pace did not pursue claims in a "diligent" and timely fashion, he was not entitled equitable tolling for any of the time period during which he pursued his state appeals.

Rotella v. Wood

Does the four year statute of limitations on claims under the Racketeer Influenced and Corrupt Organizations Act begin to run before a claimant actually discovers that a defendant's racketeering activity caused the harm?

Yes. In a unanimous opinion delivered by Justice David H. Souter, the Court held that Rotella's action was not timely, because the start of the 4-year limitations period applicable to a civil RICO action was not governed by an "injury and pattern discovery" accrual rule under which such a civil claim would accrue only when the claimant discovered, or should have discovered, both an injury and a pattern of racketeering activity. In a footnote, Justice Souter noted that "[w]e do not...settle upon a final rule."

Soriano v. United States

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Woodford v. Ngo

Does a prisoner satisfy the Prison Litigation Reform Act of 1995's requirement that he exhaust all administrative remedies available to him before bringing suit in federal court by filing an untimely or otherwise procedurally defective administrative grievance which is rejected?

No. In a 6-to-3 decision authored by Justice Samuel Alito, the Supreme Court held that a prisoner must properly exhaust any available administrative remedies before bringing suit in federal court. This understanding of the PLRA's exhaustion provision mirrors that of the traditional exhaustion provision in administrative law and is "substantively similar" to that of habeas corpus law. An alternative ruling, Justice Alito wrote, would allow prisoners to circumvent the obvious purpose of the act (channeling initial appeals through the administrative system rather than the courts) by simply waiting until their administrative appeals were no longer timely.