Rotkiske v. Klemm, 589 U.S. 8

Rotkiske incurred credit-card debt referred to Klemm & Associates, which sued in state court in 2008–2009 using service at an address where Rotkiske no longer lived; a third party accepted service and Klemm obtained a default judgment in 2009.
Rotkiske alleges he did not learn of the default judgment until 2014 when a mortgage application was denied; he filed an FDCPA suit in 2015 claiming Klemm violated the FDCPA by attempting collection without lawful ability to collect (i.e., by filing a time-barred suit).
The FDCPA authorizes private actions to be brought “within one year from the date on which the violation occurs” (15 U.S.C. §1692k(d)).
Klemm moved to dismiss as time-barred; the district court dismissed relying on the statute’s plain text; the Third Circuit (en banc) affirmed, rejecting a general discovery rule and noting Rotkiske had not preserved equitable- tolling/discovery arguments.
The Supreme Court granted certiorari to resolve the circuit split and held that, absent an applicable equitable doctrine, §1692k(d)’s limitations period begins when the violation occurs, not when it is discovered; the Court declined to decide whether equitable doctrines might apply because Rotkiske did not preserve that argument.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a general discovery rule delays start of §1692k(d)’s one‑year period	Rotkiske: courts should read a discovery rule into §1692k(d) so limitations run from discovery of violation	Klemm: statute’s plain language fixes the start at the date the violation occurs; no judicially imposed discovery rule	Held: No general discovery rule; limitations run from date violation occurs (text controls).
Whether a fraud‑specific equitable discovery rule excuses late filing	Rotkiske: alleged fraudulent service (“sewer service”) concealed the suit and justifies applying a fraud discovery rule	Klemm: limitations bar applies; plaintiff failed to preserve or timely raise equitable‑discovery argument	Held: Court did not decide merits because Rotkiske forfeited/preserved issue inadequately; noted such equitable doctrines exist but were not presented here.

TRW Inc. v. Andrews, 534 U.S. 19 (2001) (discusses accrual and discovery rules for federal limitations periods)
Merck & Co. v. Reynolds, 559 U.S. 633 (2010) (recognizes fraud‑discovery rule as equity‑based)
Bailey v. Glover, 88 U.S. 342 (1875) (historic source for fraud‑based discovery rule)
Holmberg v. Armbrecht, 327 U.S. 392 (1946) (equity tolling/discovery in fraud cases)
Gabelli v. SEC, 568 U.S. 442 (2013) (accrual rule and distinction between accrual and equitable tolling)
Connecticut Nat. Bank v. Germain, 503 U.S. 249 (1992) (statutory interpretation: clear text ends inquiry)
Bay Area Laundry & Dry Cleaning Pension Trust Fund v. Ferbar Corp., 522 U.S. 192 (1997) (accrual principles and presumption that claims accrue when cause of action is complete)