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Nutraceutical Corp. v. Lambert

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Supreme Court of the United States
Nutraceutical Corp. v. Lambert
Term: 2018
Important Dates
Argument: November 27, 2018
Decided: February 26, 2019
Outcome
United States Court of Appeals for the 9th Circuit reversed and remanded
Vote
9-0
Majority
Chief Justice John G. Roberts • Clarence Thomas • Ruth Bader Ginsburg • Stephen Breyer • Samuel Alito • Sonia Sotomayor • Elena Kagan • Neil Gorsuch • Brett Kavanaugh

Nutraceutical Corp. v. Lambert is a case argued before the Supreme Court of the United States on November 27, 2018, during the court's 2018-2019 term.

In a unanimous ruling, the court reversed and remanded the ruling of the United States Court of Appeals for the Ninth Circuit, holding that "Rule 23(f) is not subject to equitable tolling." Rule 23(f) establishes a 14-day deadline to seek permission to appeal an order granting or denying class certification.[1][2]

HIGHLIGHTS
  • The case: Troy Lambert filed a class action lawsuit against Nutraceutical Corp. for allegedly making false claims about a dietary supplement that was supposed to increase sexual performance. After a district court declined to let the class action move forward, Lambert filed an appeal, but he did not do so within 14 days, as required by the court.
  • The issue: Whether the U.S. Court of Appeals for the 9th Circuit erred when it held that equitable exceptions apply to mandatory claim-processing rules—such as Federal Rule of Civil Procedure 23(f), which establishes a 14-day deadline to file a petition for permission to appeal an order granting or denying class-action certification—and can excuse a party’s failure to file timely within the deadline specified by Federal Rule of Civil Procedure 23(f), in conflict with the decisions of the U.S. Courts of Appeals for the 2nd, 3rd, 4th, 5th, 7th, 10th and 11th Circuits.[3]
  • The outcome: The Supreme Court reversed and remanded the ruling of the United States Court of Appeals for the Ninth Circuit, holding that "Rule 23(f) is not subject to equitable tolling." Rule 23(f) establishes a 14-day deadline to seek permission to appeal an order granting or denying class certification.[2]


    • You can review the lower court's opinion here.[4]

    Timeline

    The following timeline details key events in this case:

    • February 26, 2019: U.S. Supreme Court reversed and remanded the case
    • November 27, 2018: Oral argument
    • June 25, 2018: U.S. Supreme Court agreed to hear case
    • February 1, 2018: Petition filed with U.S. Supreme Court
    • September 15, 2018: Ninth Circuit Court reversed district court’s decision and remanded case

    Background

    Troy Lambert purchased a dietary supplement made by Nutraceutical that the company claimed would enhance sexual performance, but the claim was not approved by the Food and Drug Administration (FDA). Lambert said that he would not have purchased the product if he had known the claim was false. Lambert filed a consumer class action lawsuit against Nutraceutical claiming that the product violated FDA regulations by not prominently displaying that the supplement was not approved by the FDA and not explaining to consumers that it contained a potentially dangerous ingredient.[5]

    A judge then granted Nutraceutical’s motion to decertify the class action because he said that Lambert did not provide enough evidence for the action to move forward. Ten days later, Lambert told the court that he intended to file a motion for reconsideration with more evidence. The court said that he had to file it within 10 days, which he did. The court denied his motion for reconsideration. Lambert then filed a petition to appeal the district court’s orders to the Ninth Circuit Court.[5]

    The Ninth Circuit Court “held that Lambert’s Rule 23(f) petition for class certification had been timely filed with the appellate court. … In this case, Lambert had informed the district court of his intention to file a motion for reconsideration within Rule 23(f)’s 14-day window, and had submitted the filing within the ten-day time frame set by that court. The panel concluded that under these circumstances the deadline should be tolled and Lambert’s motion for reconsideration should be considered timely filed with the 9th Circuit,” according to Oyez.[5]

    Nutraceutical appealed to the Supreme Court, and the court agreed to hear the case on June 25, 2018.

    Question presented

    The petitioner presented the following question to the court:[3]

    Question presented:
    • Whether the U.S. Court of Appeals for the 9th Circuit erred when it held that equitable exceptions apply to mandatory claim-processing rules—such as Federal Rule of Civil Procedure 23(f), which establishes a 14-day deadline to file a petition for permission to appeal an order granting or denying class-action certification—and can excuse a party’s failure to file timely within the deadline specified by Federal Rule of Civil Procedure 23(f), in conflict with the decisions of the U.S. Courts of Appeals for the 2nd, 3rd, 4th, 5th, 7th, 10th and 11th Circuits.

    Audio

    • Audio of oral argument:[6]

    Transcript

    • Read the oral argument transcript here.

    Outcome

    Decision

    Justice Sonia Sotomayor delivered the unanimous opinion of the court. The court reversed and remanded the ruling of the Ninth Circuit, holding that "Rule 23(f) is not subject to equitable tolling." Rule 23(f) establishes a 14-day deadline to seek permission to appeal an order granting or denying class certification.[2]

    Opinion

    In her opinion for the court, Justice Sotomayor wrote,

    “ The relevant Rules of Civil and Appellate Procedure clearly foreclose the flexible tolling approach on which the Court of Appeals relied to deem Lambert’s petition timely. The judgment of the Court of Appeals is therefore reversed, and the case is remanded for further proceedings consistent with this opinion.[7] ”

    Text of the opinion

    • Read the full opinion here.

    See also

    External links

    Footnotes

    1. ↑ Supreme Court of the United States, "17-1094 Nutraceutical Corp. v. Lambert," accessed October 29, 2018
    2. ↑ 2.0 2.1 2.2 2.3 United States Supreme Court, "Nutraceutical Corp. v. Lambert," Opinion, February 26, 2019
    3. ↑ 3.0 3.1 Supreme Court of the United States, "17-1094 Nutraceutical Corp. v. Lambert," accessed October 29, 2018
    4. ↑ SCOTUSblog, "Nutraceutical Corp. v. Lambert," accessed October 29, 2018
    5. ↑ 5.0 5.1 5.2 Oyez, "Nutraceutical Corp. v. Lambert," accessed October 30, 2018
    6. ↑ Supreme Court of the United States, Nutraceutical Corp. v. Lambert, argued November 27, 2018
    7. ↑ Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
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