Nutraceutical Corp. v. Lambert, 586 U.S. 188

Troy Lambert sued Nutraceutical Corp. alleging deceptive marketing and obtained class certification, which the district court decertified on February 20, 2015.
Federal Rule of Civil Procedure 23(f) then required a petition for permission to appeal the decertification be filed in the court of appeals within 14 days.
Lambert told the district court on March 2 (10 days after decertification) he intended to file a motion for reconsideration and was told to file by March 12; he filed on March 12 (20 days after decertification).
The district court denied reconsideration on June 24; Lambert filed a Rule 23(f) petition in the Ninth Circuit on July 8, which Nutraceutical opposed as untimely.
The Ninth Circuit deemed the petition timely by applying equitable tolling and reversed the decertification; the Supreme Court granted certiorari to decide whether Rule 23(f)’s 14-day deadline can be tolled.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether courts of appeals may apply equitable tolling to Rule 23(f)’s 14-day petition deadline	Lambert: equitable tolling should apply where parties acted diligently and circumstances warranted	Nutraceutical: Rule 23(f) deadline is mandatory under the Federal Rules and cannot be tolled	The 14-day Rule 23(f) deadline is not subject to equitable tolling when the opposing party properly raises the timeliness objection
Whether Appellate Rule 26(b)’s prohibition on extending time to file leaves room to "permit" late filings after the fact	Lambert: Rule 26(b)(1) bars only preemptive extensions, not post-deadline equitable excusal	Nutraceutical: permitting late filings effectively enlarges the filing period and is forbidden by the Rules	The Court held Robinson controls: allowing late filings enlarges the period and Rule 26(b)(1) forecloses such post hoc exceptions
Whether a motion for reconsideration filed within 14 days tolls the Rule 23(f) clock	Lambert: if reconsideration motion is timely, appeal time runs from resolution of that motion	Nutraceutical: timely reconsideration renders the decision not final (affecting when the 14-day window begins), not a matter of tolling	The Court noted timely reconsideration affects the start of the appeal clock (not tolling) and left preservation and merits of that argument to the court of appeals on remand

Carlisle v. United States, 517 U.S. 416 (1996) (interpreting a rule barring extensions and holding courts cannot accept untimely filings when text forecloses it)
Robinson v. United States, 361 U.S. 220 (1960) (holding that permitting a late filing is equivalent to enlarging the filing period and is prohibited by the applicable rule)
Kontrick v. Ryan, 540 U.S. 443 (2004) (distinguishing jurisdictional rules from claim-processing rules and discussing waiver/forfeiture)
Bank of Nova Scotia v. United States, 487 U.S. 250 (1988) (courts must enforce properly raised procedural rules according to their plain import)
United States v. Ibarra, 502 U.S. 1 (1991) (timely postjudgment motions render a decision not final for purposes of appeal; not a tolling doctrine)
Mohawk Industries, Inc. v. Carpenter, 558 U.S. 100 (2009) (interlocutory appeals are the exception and require careful calibration)
Torres v. Oakland Scavenger Co., 487 U.S. 312 (1988) (permitting jurisdiction over unnamed parties after appeal time is equivalent to extending the appeal period)
Budinich v. Becton Dickinson & Co., 486 U.S. 196 (1988) (earlier characterizations of some time limits as jurisdictional, contrasted with later clarifications about such labels)