Vega-Ruiz v. Northwell Health, 992 F.3d 61

Plaintiff Lissette Vega-Ruiz is profoundly deaf and primarily communicates via American Sign Language (ASL).
On October 13, 2015, while acting as her brother’s health-care proxy at a Northwell hospital, Vega‑Ruiz requested an ASL interpreter but was given a Spanish interpreter who relied on written notes and lip reading.
Vega‑Ruiz sued on January 28, 2019 alleging disability discrimination under the Affordable Care Act (ACA), 42 U.S.C. § 18116(a).
The district court dismissed the complaint on January 14, 2020 as time‑barred, concluding the claim was effectively a Rehabilitation Act claim and thus governed by New York’s three‑year limitations period.
The Second Circuit reviewed whether Vega‑Ruiz’s claim “arises under” the ACA for purposes of 28 U.S.C. § 1658(a), which provides a four‑year federal catchall statute of limitations for post‑1990 Acts of Congress lacking their own limitations period.
The court held the ACA changed defendant obligations (extending the ADA/Title II “primary consideration” standard to entities like hospitals) so Vega‑Ruiz’s claim was “made possible by” the ACA; § 1658’s four‑year period applies, the claim was timely, and the judgment was vacated and remanded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Which statute of limitations governs Vega‑Ruiz’s disability discrimination claim — the four‑year federal catchall under 28 U.S.C. § 1658 (post‑1990 Acts) or the three‑year state personal‑injury period applied to Rehabilitation Act claims?	Vega‑Ruiz: She sued under the ACA; the ACA is a post‑1990 Act without its own limitations period, so § 1658’s four‑year period applies.	Northwell: The ACA borrows enforcement mechanisms from the Rehabilitation Act; the claim is effectively a Rehabilitation Act claim subject to the three‑year state limitations period.	The court held the claim was ‘‘made possible by’’ the ACA (which extended Title II ‘‘primary consideration’’ obligations to entities like hospitals), so § 1658’s four‑year limitations period applies; the claim is timely.

Jones v. R.R. Donnelly & Sons Co., 541 U.S. 369 (2004) (§ 1658 applies if a claim was "made possible by" a post‑1990 Act; interpret "arising under" broadly)
Morse v. Univ. of Vermont, 973 F.2d 122 (2d Cir. 1992) (courts borrow state limitations for federal statutes lacking an express limitations period)
Goodman v. Lukens Steel Co., 482 U.S. 656 (1987) (background on borrowing state limitations when federal statute is silent)
Bates v. Long Island R.R. Co., 997 F.2d 1028 (2d Cir. 1993) (New York’s three‑year personal‑injury statute applies to Rehabilitation Act claims)
McElwee v. Cnty. of Orange, 700 F.3d 635 (2d Cir. 2012) (Rehabilitation Act standards align with the ADA)
Skidmore v. Swift & Co., 323 U.S. 134 (1944) (agency interpretations may have persuasive weight under Skidmore deference)
De La Mota v. United States Dep’t of Educ., 412 F.3d 71 (2d Cir. 2005) (applying Skidmore to assess weight of agency interpretations)