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Artis v. District of Columbia

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Supreme Court of the United States
Artis v. District of Columbia
Term: 2017
Important Dates
Argument: November 1, 2017
Decided: January 22, 2018
Outcome
D.C. Circuit reversed
Vote
5-4 to reverse
Majority
Chief Justice John G. Roberts • Ruth Bader Ginsburg • Stephen Breyer • Sonia Sotomayor • Elena Kagan
Dissenting
Neil Gorsuch • Samuel Alito • Anthony Kennedy • Clarence Thomas


Artis v. District of Columbia is a case argued during the October 2017 term of the U.S. Supreme Court. Argument in the case was held on November 1, 2017. The case came on a writ of certiorari to the District of Columbia Court of Appeals.

HIGHLIGHTS
  • The case: While awaiting a ruling from a federal district court on work-related claims filed against her former employer, Stephanie Artis' three-year statute of limitations period in which to file similar claims in D.C. local courts expired. Artis filed claims against the District of Columbia 59 days after a federal court determined it lacked jurisdiction over some of Artis' claims. Artis claimed that the statute of limitations was tolled, or suspended, pending the outcome of the federal district court under 28 U.S.C. §1367(d). The District countered that 28 U.S.C. §1367(d)'s tolling provision only granted a 30-day grace period in which to refile and that, because Artis exceeded that 30-day grace period, her suit was untimely. Both a local judge and a D.C. appeals court panel sided with the District.
  • The issue: Does 28 U.S.C. §1367(d)'s tolling provision suspend a statute of limitations period in which to file a lawsuit entirely or does 28 U.S.C. §1367(d) provide only a 30-day grace period for a plaintiff to refile claims in a state or local court once a federal court determines that the federal court lacks jurisdiction?
  • The outcome: The U.S. Supreme Court reversed the D.C. Circuit, concluding that the statute of limitations was suspended while the federal district case was pending.


    • You can review the lower court's opinion here.[1]

    Background

    This was a case about timing. Most legal claims are subject to a statute of limitations. A statute of limitations governs the amount of time a prospective plaintiff has to file a claim. From 2007 to 2010, Stephanie Artis, the petitioner, was employed as a temporary health code inspector in the District of Columbia. Beginning in 2009 and continuing through her remaining work period for the District, she filed numerous work-related claims against her supervisor, Gerard Brown. Artis was fired in November of 2010. In December of 2011, Artis filed a civil suit in federal district court alleging that her termination violated Title VII of the Civil Rights Act of 1964 as well as two District ordinances, the District's Whistleblower Act and the District's False Claims Act. Artis also alleged a common law violation that her wrongful termination violated public policy. In June of 2014, the federal court dismissed Artis' Title VII discrimination claim and ruled that Artis' statutory claims were outside of the federal court's jurisdiction.

    59 days after Artis' claims were dismissed by the federal district court, she filed a lawsuit in a local court, the Superior Court of the District of Columbia. The District, her former employer, filed a motion to dismiss Artis' lawsuit alleging the suit was time barred based both on the District's three-year statute of limitations to file such claims and under a federal law, 28 U.S.C. §1367(d). Judge Herbert Dixon agreed with the District. Dixon held that 28 U.S.C. §1367(d) only allows for a 30-day grace period to refile claims in a state or local court once a federal district court determines that the federal court lacks jurisdiction--that is, determines that it lacks the legal authority to rule on those claims. Because Artis filed her claims beyond the 30-day grace period, Judge Dixon held that Artis' suit was time-barred and dismissed the lawsuit.[1]

    Artis appealed the dismissal of her lawsuit against the District to the District of Columbia Court of Appeals. The D.C. appellate court considers appeals from the Superior Court of the District of Columbia. Artis claimed that Judge Dixon misinterpreted the word "tolled" in 28 U.S.C. §1367(d). Tolling in legal terms means to suspend. At the time of her appeal, 28 U.S.C. §1367(d) said, "[t]he period of limitations for any claim asserted under subsection (a), and for any other claim in the same action that is voluntarily dismissed at the same time as or after the dismissal of the claim under subsection (a), shall be tolled while the claim is pending and for a period of 30 days after it is dismissed unless State law provides for a longer tolling period."[1]

    Here, Artis alleged that the word "tolled" under 28 U.S.C. §1367(d) meant that the statute of limitations to file claims against the District in the Superior Court of the District of Columbia was suspended (tolled) while she pursued actions in federal court. At the time Artis filed her federal lawsuit, there were nearly two years remaining on the statute of limitations to file her claims in the local court, but because the federal district court took three years to rule on her claims, the statute of limitations to file in local court passed. Artis argued that she should have had that two-year period plus the 30-day grace period under 28 U.S.C. §1367(d) to file her claims against the District, not just the 30-day window as the District alleged. Artis grounded her reasoning based on the interpretation of 28 U.S.C. §1367(d) adopted by the Maryland Court of Appeals in Turner v. Knight. That court held that the word "tolled" under 28 U.S.C. §1367(d) meant "to suspend the local statute of limitations at the point the federal suit was filed."[1]

    The District, however, urged the appeals court to adhere to the interpretation of the California Supreme Court in City of Los Angeles v. County of Kern. As Judge Dixon held in dismissing Artis' lawsuit, the District argued that "in the context of the statute’s language, purpose, and history, 'tolled' means a thirty-day 'grace period' will apply if the limitations period for the state based claims expires while the claim is pending in the federal court. Here ... the limitations period had expired while the federal suit was pending, so appellant had only thirty days to file in Superior Court."[1]

    Before a three-judge panel of the District of Columbia Court of Appeals composed of Judges Anna Blackburne-Rigsby, John R. Fisher, and William C. Pryor, the court upheld Judge Dixon's order dismissing Artis' lawsuit. In a unanimous opinion authored by Judge Pryor, the court distinguished between what it dubbed "the suspension approach," which was advocated by Artis, and the "grace period approach" advanced by the District. The court acknowledged that "the parties have advanced two respective positions which are consistent with the competing approaches that have evolved nationally relating to the tolling provision of the statute presented." However, in analyzing the approach of the federal appeals courts that have reviewed the statute, the legislative history, and legislative intent of Congress in passing 28 U.S.C. §1367(d), the court felt that the "grace period approach" was superior. Judge Pryor wrote,[1]

    “

    Not only are we satisfied that the 'grace period' approach conforms with § 1367 (d)’s purpose and history, we also find it consistent with our presumption favoring narrow interpretations of federal preemption of state law. ... This is not the first time we have been asked to interpret 28 U.S.C. § 1367 (d). ... we reversed a trial court finding that § 1367 (d) did not permit appellant to file her dismissed action in Superior Court after the district court determined it lacked subject-matter jurisdiction. There, appellant filed her underlying tort claim in Superior Court within thirty days of its dismissal from the district court, making it unnecessary for us to expressly interpret the meaning of 'tolled.' Nevertheless, we commented that application of § 1367 (d)’s thirty-day extension to the 'local statute of limitations' was necessary to satisfy the statute’s purpose of allowing parties to 'economically resolve related matters in a single forum' and 'increase the administrative efficiency of the civil litigation process' without having to file 'duplicative and wasteful protective suits in state court.'[2]

    		”

    In concluding that 28 U.S.C. §1367(d)'s tolling provision allows a maximum, 30-day grace period to refile claims the D.C. Superior Court once a federal court determined that it lacked jurisdiction, and finding that Artis' filing exceeded both that 30-day grace period as well as the District's three-year statute of limitations, the court affirmed Judge Dixon's decision to dismiss her lawsuit.[1]

    Petitioner's challenge

    Stephanie Artis, the petitioner, challenged the holding of the District of Columbia Court of Appeals. Artis argued that the tolling provision of 28 U.S.C. § 1367 (d) does not limit her time to refile claims to just a 30-day grace period once a federal court determined that it lacked jurisdiction, but that the provision instead suspended the statute of limitations entirely. In this interpretation, her filing in the Superior Court of the District of Columbia 59 days after her case was dismissed in federal district court for want of jurisdiction was timely and should not have been dismissed in the D.C. local court.

    Certiorari granted

    On October 6, 2016, Stephanie Artis, the petitioner, initiated proceedings in the Supreme Court of the United States in filing a petition for a writ of certiorari to the District of Columbia Court of Appeals. The U.S. Supreme Court granted Artis' certiorari request on February 27, 2017. Argument in the case was held on November 1, 2017.[3]

    Question presented

    Question presented:

    "Whether the tolling provision in 28 U.S.C. § 1367(d) suspends the limitations period for the state-law claim while the claim is pending and for 30 days after the claim is dismissed, or whether the tolling provision does not suspend the limitations period but merely provides 30 days beyond the dismissal for the plaintiff to refile."[3]

    Audio

    • Audio of oral argument:[4]



    Transcript

    • Transcript of oral argument:[5]

    Outcome

    Decision

    Justice Ruth Bader Ginsburg delivered the opinion of the court. The court held that the tolling provision suspended the statute of limitations clock while the federal case was pending, giving Artis the remainder of the statute of limitations period plus 30 days to file her claim in a D.C. local court.

    Majority opinion

    Justice Ginsburg ruled that the statute's "instruction to 'toll' a state limitations period means to hold it in abeyance, i.e., to stop the clock."[6] Ginsburg first turned to the language of the statute and the textual meaning of the word toll. Examining other statutes and sources, she wrote, "Ordinarily, tolled, in the context of a time prescription like §1367(d), means that the limitations period is suspended (stops running) while the claim is sub judice elsewhere, then starts running again when the tolling period ends, picking up where it left off." She directly addressed the dissent's counter-argument:

    “ Tellingly, the District has not identified any federal statute in which a grace-period meaning has been ascribed

    to the word “tolled” or any word similarly rooted. Nor has the dissent, for all its mighty strivings, identified even one federal statute that fits its bill, i.e., a federal statute that says 'tolled' but means something other than 'suspended,' or 'paused,' or stopped.'...Our decisions employ the terms 'toll' and 'suspend' interchangeably.[6][2]

    		”

    Ginsburg also addressed whether the court's ruling created any constitutional concerns over the reach of Congress' power and states' rights to make their own laws. She cited an earlier Supreme Court opinion, Jinks v. Richland County, and concluded, "In Jinks, we unanimously rejected an argument that §1367(d) impermissibly exceeds Congress’ enumerated powers." Based on Jinks, Ginsburg rejected the argument that finding in Artis' favor intruded on state sovereignty:

    “ The concern that a stop-the-clock prescription entails a greater imposition on the States than a grace-period prescription, moreover, may be more theoretical than real. Consider the alternative suggested by the D. C. Superior Court. Plaintiffs situated as Artis was could simply file two actions and ask the state court to hold the suit filed there in abeyance pending disposition of the federal suit.Were the dissent’s position to prevail, cautious plaintiffs would surely take up the D. C. Superior Court’s suggestion. How it genuinely advances federalism concerns to drive plaintiffs to resort to wasteful, inefficient duplication to preserve their state-law claims is far from apparent.[6][2] ”

    Ginsburg concluded, "For the reasons stated, we resist unsettling the usual understanding of the word “tolled” as it appears in legislative time prescriptions and court decisions thereon." The majority reversed the D.C. Circuit's decision.[6]

    Dissenting opinion

    Justice Neil Gorsuch authored the dissent, which was joined by Justices Kennedy, Thomas, and Alito. Gorsuch wrote, "It may only be a small statute we are interpreting, but the result the Court reaches today represents no small intrusion on traditional state functions and no small departure from our foundational principles of federalism."

    Gorsuch first turned to the textual meaning of the word toll. He cited dictionary definitions of the term and concluded, "It can, naturally enough, mean either that the running of the limitations period is suspended or that the effect of the limitations period is defeated." Gorsuch wrote, "The stop clock approach was often used at common law to suspend a plaintiff ’s duty to bring a timely lawsuit if, and for the period, the plaintiff was prevented from coming to court due to some disability...By contrast, the grace period approach was commonly used in cases where, as here, the plaintiff made it to court in time but arrived in the wrong court and had to refile in the right one." He concluded, "Section 1367(d)’s “tolling” provision seeks to provide the plaintiff who finds her case dismissed because she filed in the wrong court a reasonable grace period to journey to the right court to refile. No more and no less."

    Gorsuch suggested that the majority's reasoning would lead to unreasonable results:

    “ The petitioner filed her suit in federal court with 23 months remaining on the three year statute of limitations. The case remained in federal district court for nearly three years before dismissal. Under the grace period approach the 30 day provision does just as it appears, providing petitioner with 30 days to journey to and refile in the correct court. Under the stop clock approach, though, the statute affords the petitioner 23 months plus a random 30 days more to refile. Indeed, on the stop clock approach the only work the 30 day period is even imaginably left to do comes in cases where the plaintiff filed her federal suit at the very end of the limitations period. And if that’s the only problem Congress sought to address, it chose a mighty murky way to do it, for the parties point to not a single stop clock provision in all of federal law that includes language anything like this. All while (again) this language fits hand in glove with every grace period statute known.[6][2] ”


    Gorsuch then turned to the constitutional question. Citing Jinks, Gorsuch wrote, "The necessary and proper federal interest Jinks recognized is fully discharged by a grace period." He concluded, "The stop clock approach...ensures that traditional state law judgments about the appropriate lifespan of state law claims will be routinely displaced—and displaced in favor of nothing more than a fortuity (the time a claim sits in federal court) that bears no rational relationship to any federal interest."[6]

    The opinion

    See also

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 1.5 1.6 District of Columbia Court of Appeals, Stephanie C. Artis v. District of Columbia, April 7, 2016
    2. ↑ 2.0 2.1 2.2 2.3 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    3. ↑ 3.0 3.1 Supreme Court of the United States, Artis v. District of Columbia, February 27, 2017
    4. ↑ Supreme Court of the United States, Artis v. District of Columbia, argued November 1, 2017
    5. ↑ Supreme Court of the United States, Artis v. District of Columbia, argued November 1, 2017
    6. ↑ 6.0 6.1 6.2 6.3 6.4 6.5 United States Supreme Court, "Artis v. District of Columbia" Opinion, January 22, 2018
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