Scott v. Government of District of Columbia
87 F. Supp. 3d 291
D.D.C.2015Background
- On April 5, 2008, Scott and Pratt were arrested in D.C. and elected the District’s "post and forfeit" procedure, paying $25 and $35 respectively to resolve misdemeanor charges.
- Their putative class claims challenging the post-and-forfeit procedure derive from that April 5, 2008 incident; a three-year statute of limitations therefore applied.
- A prior putative class action—Fox v. District of Columbia—was filed on December 15, 2010, asserting similar class claims; Scott and Pratt contend Fox tolled the limitations period under American Pipe.
- Judge Jackson dismissed the Fox class claims in stages (March 30, 2012 and February 15, 2013), leaving only individual claims; final judgment on Fox’s individual claims occurred later by settlement.
- Plaintiffs filed the present suit on May 16, 2014. The District moved to dismiss as time-barred and for failure to state a claim; the Court held tolling ended when all class claims in Fox were dismissed and dismissed Scott and Pratt’s complaint as untimely.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether American Pipe tolling continued through the end of the Fox case or ended when Fox’s class claims were dismissed | Tolling continued until final judgment in Fox (including individual claims); therefore Scott and Pratt’s suit was timely | Tolling ended when the last class claim in Fox was dismissed; plaintiffs’ remaining limitations period ran and expired before filing | Tolling ended when all class claims were dismissed; Scott and Pratt’s suit was untimely and dismissed for lack of jurisdiction |
| Whether the Court must reach merits (failure to state a claim) after finding lack of jurisdiction | N/A (plaintiffs focused on timeliness) | N/A | Because claims were time-barred and subject-matter jurisdiction lacking, the Court did not reach Rule 12(b)(6) merits analysis |
Key Cases Cited
- American Pipe & Construction Co. v. Utah, 414 U.S. 538 (tolling doctrine for putative class members)
- Crown, Cork & Seal Co. v. Parker, 462 U.S. 345 (limits of American Pipe tolling tied to reasonable reliance interests)
- Sawyer v. Atlas Heating & Sheet Metal Works, Inc., 642 F.3d 560 (7th Cir. 2011) (tolling ends when suit is "conclusively not a class action")
- Bridges v. Dep’t of Maryland State Police, 441 F.3d 197 (4th Cir. 2006) (American Pipe tolling extends only as justified by absent members’ reasonable reliance)