BNSF Railway Co. v. Cringle
2012 MT 143
| Mont. | 2012Background
- Cringle filed a July 7, 2008 discrimination complaint with Montana DLI against BNSF; hearing officer granted liability on May 1, 2009 and issued final decision September 2, 2009; notice of the decision was mailed the same day; BNSF received the notice September 3, 2009 but staff misplaced it for 19 days; the decision became final if not appealed within 14 days after notice, i.e., by September 16, 2009; BNSF filed a notice of appeal to the Commission and requested an extension; Commission denied the extension and dismissed the appeal; Cringle moved to dismiss BNSF’s petition for judicial review arguing the filing deadline was jurisdictional or, at minimum, a strict time bar; on remand the district court found “good cause” to excuse the late filing and remanded to the Commission; on review this Court held the 14-day deadline is a rigid time prescription subject to constitutional review and equitable principles but requires a showing beyond ordinary neglect for relief; the district court’s July 11, 2011 order reversing the commission was improper; this Court reverses and denies BNSF’s petition, entering judgment for Cringle.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the 14-day filing deadline is a jurisdictional bar. | Cringle argues the deadline is nonjurisdictional; BNSF seeks extension. | BNSF argues the district court could equitably toll or extend the deadline. | Deadline is a rigid time prescription, not jurisdictional; may be subject to limited equitable relief. |
| What standard applies to excusing noncompliance with the deadline. | Cringle maintains standard is strict good cause with substantial justification. | BNSF urges a more lenient, tolling-based standard. | A higher, legally sufficient reason is required; not equivalent to equitable tolling. |
| Did the district court properly apply good-cause analysis on remand? | Cringle asserts the district court failed to demand legally sufficient good cause. | BNSF argues the court properly recognized good cause given misplacement and timely correction. | District Court erred; no legally sufficient good cause shown. |
| Should the court apply equitable tolling or a good-cause standard to this categorical deadline? | Cringle supports applying a stricter standard; no tolling. | BNSF prefers applying equitable tolling. | The Court rejects broad equitable tolling; applies a strict good-cause framework. |
Key Cases Cited
- Puhto v. Smith Funeral Chapels, Inc., 362 Mont. 447 (Mont. 2011) (denying relief for layperson’s inattention to mail; duty to monitor litigation)
- Lozeau v. GEICO Indem. Co., 350 Mont. 320 (Mont. 2009) (applied equitable tolling to a time bar despite categoric language)
- Weidow v. Uninsured Employers’ Fund, 2010 MT 292 (Mont. 2010) (applied equitable tolling in some contexts; cautioned against one-size-fits-all approach)
- Arthur v. Pierre Ltd., 2004 MT 303 (Mont. 2004) (rejected broad tolling for equal rights actions; emphasized diligence required)
- Irwin v. Dept. of Veterans Affairs, 498 U.S. 89 (1990) (equitable tolling generally applicable to private-litigant time limits)
- Holland v. Florida, 130 S. Ct. 2549 (2010) (recognizes equitable tolling where consistent with statute's purposes)
- Brockamp v. United States, 519 U.S. 347 (1997) (limits tolling where statute shows clear intent to foreclose)
- Day v. McDonough, 547 U.S. 198 (2006) (judicial interpretation of tolling in discretionary contexts)
- United States v. Beggerly, 524 U.S. 38 (1998) (tolling not allowed where inconsistent with statute text)
- Greenlaw v. U.S., 554 U.S. 237 (2008) (finality and notice principles supporting strict timelines)