Supreme Court considers meaning of ‘tolled’ under federal supplemental jurisdiction statute News
Supreme Court considers meaning of ‘tolled’ under federal supplemental jurisdiction statute

The US Supreme Court [official website] heard oral arguments [transcript, PDF] Wednesday in Artis v. District of Columbia [SCOTUSblog materials], involving the meaning of a provision of the federal supplemental jurisdiction statute [text], which allows plaintiffs to pursue state court claims after related federal claims are dismissed.

Under the doctrine of supplemental jurisdiction, as long as the federal court has subject-matter jurisdiction [Cornell LII backgrounder] over the federal claim(s), the court may also hear the state claims, even if those claims would not independently qualify for federal adjudication. In some cases, a federal court may end up dismissing the federal claims, and because the state claims do not independently qualify, the state claims are also dismissed. In those instances, the plaintiff may try to refile those claims in state court.

In this case, the Court must determine how much time the federal supplemental jurisdiction statute gives plaintiffs to re-file in state court. More specifically, the justices will decide whether the statute provides plaintiffs with a 30-day window after the dismissal of their claims to refile, or if the plaintiffs are given 30 days plus the remaining limitations period at the time the plaintiff filed the original federal suit. The statute provides:

The period of limitations for any claim asserted under subsection (a), and for any other claim in the same action that is voluntarily dismissed at the same time as or after the dismissal of the claim under subsection (a), shall be tolled while the claim is pending and for a period of 30 days after it is dismissed unless State law provides for a longer tolling period” [emphasis added].

The District of Columbia Court of Appeals affirmed [opinion, PDF] the lower court’s ruling that the word “tolled” in this section is ambiguous.

Both parties in this case reject the court of appeals’ determination and argue that the term is decisive. Plaintiffs argue that the provision should be interpreted as a “stop-clock” provision, pausing the statute of limitations for supplemental claims while the claims that are pending in federal court and for 30 days after dismissal. The defendants argue that the statute of limitations should continue to run while the federal claim is pending and that the statute provides 30 days after dismissal to re-file in state court.

Either way, the court’s holding will affect the timing of litigation around the country and give plaintiffs more certainty about their filing deadlines.