Artis v. District of Columbia
138 S. Ct. 594
| SCOTUS | 2018Background
- Stephanie Artis sued the District of Columbia in federal court asserting one federal (Title VII) claim and three related D.C. law claims; the federal court granted summary judgment on the federal claim and declined supplemental jurisdiction over the state claims under 28 U.S.C. §1367(c)(3).
- §1367(d) provides: “The period of limitations for any [state] claim ... 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.”
- When Artis originally filed in federal court nearly two years remained on the state statutes of limitations; about 2.5 years later the federal court dismissed her federal claim and the state claims; Artis refiled in D.C. Superior Court 59 days after dismissal.
- D.C. Superior Court dismissed her refiling as time-barred; the D.C. Court of Appeals affirmed, adopting a “grace-period” reading that §1367(d) only provides a 30‑day window after dismissal rather than suspending (stopping) the limitations clock during federal pendency.
- The Supreme Court granted certiorari to decide whether “tolled” in §1367(d) means (a) stop-the-clock (suspend the limitations period while the claim is pending in federal court and resume afterward) or (b) a grace period (limitations continue to run but plaintiff gets 30 days after dismissal to refile).
Issues
| Issue | Plaintiff's Argument (Artis) | Defendant's Argument (District) | Held |
|---|---|---|---|
| Does §1367(d)’s instruction to “toll” mean suspend (stop-the-clock) or provide only a 30‑day grace period after dismissal? | “Toll” means suspend the limitations period while the claim is pending in federal court and then restart the clock when tolling ends (i.e., stop the clock + 30 days). | “Toll” means remove or defeat the effect of the limitations period so that the limitations continue to run but plaintiff receives a fixed 30‑day grace period after dismissal to refile. | Court held “toll” means suspend the limitations period (stop the clock) while pending in federal court and for 30 days after dismissal. |
| Does legislative history (ALI recommendation) show Congress intended a 30‑day grace period, not suspension? | Congress drafted §1367(d) as a tolling (suspension) provision; ALI’s formulation differed and Congress did not adopt ALI’s grace-period text. | D.C. Court of Appeals and District argued §1367(d) implements ALI’s 30‑day grace recommendation. | Court held Congress did not adopt the ALI grace-period formulation and the text supports suspension. |
| Does adopting stop-the-clock tolling create constitutional or federalism problems (Necessary and Proper / state sovereignty)? | Tolling is standard, serves federal judicial administration, and was upheld in Jinks; it does not unconstitutionally intrude on states. | Stop-the-clock displaces many state limitations choices and may exceed Congress’ power or improperly intrude on state sovereignty; avoid constitutional doubt by adopting grace-period reading. | Court held Jinks controls: §1367(d) is a valid, necessary-and-proper accommodation of federal judicial function and does not present a serious constitutional problem. |
| Effect of the 30‑day clause and state-law proviso: does it undermine stop-the-clock reading? | The 30‑day post-dismissal window functions as an added short buffer to the suspension; the proviso allows a state to provide a longer tolling scheme. | The 30‑day inclusion implies Congress meant a limited grace window, not suspension. | Court held the 30 days is consistent with suspension statutes that commonly append short fixed windows; the proviso preserves more generous state rules. |
Key Cases Cited
- United States v. Detroit Timber & Lumber Co., 200 U.S. 321 (discussed syllabus usage; not part of opinion)
- Hardin v. Straub, 490 U.S. 536 (1989) (one unusual instance where Court used tolling language to describe a grace period)
- Chardon v. Fumero Soto, 462 U.S. 650 (1983) (explains different tolling effects and uses ‘‘toll’’ to mean suspension)
- American Pipe & Construction Co. v. Utah, 414 U.S. 538 (1974) (characterized its rule as ‘‘tolling’’ and applied a stop‑the‑clock approach)
- Jinks v. Richland County, 538 U.S. 456 (2003) (upheld §1367(d) as necessary and proper and recognized the need for a federal tolling rule)
- Raygor v. Regents of Univ. of Minn., 534 U.S. 533 (2002) (described §1367(d) as tolling the state statute of limitations for the period pending in federal court plus 30 days)