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AN E-BULLETIN
LEGAL INFORMATION INSTITUTE -- CORNELL LAW SCHOOL
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The following decisions have just arrived via the LII's
direct Project HERMES feed from the Supreme Court.
- Middleton v. McNeil <
http://supct.law.cornell.edu/supct/html/03-1028.ZPC.html >
- Johnson v. California <
http://supct.law.cornell.edu/supct/html/03-6539.ZPC.html >
- Scarborough v. Principi <
http://supct.law.cornell.edu/supct/html/02-1657.ZS.html >
- Dretke v. Haley < http://supct.law.cornell.edu/supct/pdf/02-1824P.ZS >
- Jones v. R. R. Donnelley & Sons Co. <
http://supct.law.cornell.edu/supct/html/02-1205.ZS.html >
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Jones v. R. R. Donnelley & Sons Co.
< http://supct.law.cornell.edu/supct/html/02-1205.ZS.html >
Opinion-author: Stevens
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SUPREME COURT OF THE UNITED STATES
JONES et al. on behalf of herself and a class of others similarly
situated v. R. R. DONNELLEY
& SONS CO.
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE SEVENTH
CIRCUIT
No. 021205. Argued February 24, 2004Decided May 3, 2004
After this Court held that federal courts should apply the most
appropriate state statute of limitations to claims arising under 42
U.S.C. 1981 which contains no statute of limitations, see Goodman v.
Lukens Steel Co., 482 U.S. 656, 660, Congress enacted a 4-year statute
of limitations for causes of action "arising under an Act of Congress
enacted after [December 1, 1990]," 28 U.S.C. 1658(a). Petitioners,
African-American former employees of respondent, filed a class action
alleging violations of 1981, as amended by the Civil Rights Act of
1991. Respondent sought summary judgment, claiming that the applicable
state 2-year statute of limitations barred their claims, but the
District Court held that petitioners wrongful discharge, refusal to
transfer, and hostile work environment claims arose under the 1991 Act
and therefore are governed by 1658. The Seventh Circuit reversed,
concluding that 1658 does not apply to a cause of action based on a
post-1990 amendment to a pre-existing statute.
Held: Petitioners causes of action are governed by 1658. Pp. 515.
(a) Because the meaning of "arising under" in 1658 is ambiguous,
Congress intent must be ascertained by looking beyond the sections
bare text to the context in which it was enacted and the purposes it
was designed to accomplish. Pp. 57.
(b) Before 1658s enactment, Congress failure to pass a uniform
limitations statute for federal causes of action had created a void
that spawned a vast amount of litigation. The settled practice of
borrowing state statutes of limitations generated a host of issues,
such as which of the forum States statutes was the most appropriate,
whether the forum States law or that of the situs of the injury
controlled, and when a statute of limitations could be tolled.
Congress was keenly aware of these problems, and a central purpose of
1658 was to minimize the need for borrowing. That purpose would not
be served if 1658 were interpreted to reach only entirely new
sections of the United States Code. An amendment to an existing
statute is no less an "Act of Congress" than a new, stand-alone
statute. What matters is the new rights of action and corresponding
liabilities created by the enactment. Thus, a cause of action
"aris[es] under an Act of Congress enacted" after December 1, 1990and
therefore is governed by 1658s 4-year statute of limitationsif the
plaintiffs claim against the defendant was made possible by a post-
1990 enactment. This construction best serves Congress interest in
alleviating the uncertainty inherent in the practice of borrowing
state statutes of limitations, while protecting litigants settled
expectations by applying only to causes of actions not available until
after December 1, 1990. It also is consistent with the common usage of
"arise" and with this Courts interpretations of "arising under" as it
is used in statutes governing the scope of federal subject-matter
jurisdiction. Pp. 713.
(c) Petitioners hostile work environment, wrongful termination,
and failure-to-transfer claims all "ar[rose] under" the 1991 Act in
the sense that they were made possible by that Act. The 1991 Act
overturned this Courts decision in Patterson v. McLean Credit Union,
491 U.S. 164, 171, which held that racial harassment relating to
employment conditions was not actionable under 1981. The Act
redefined 1981s key "make and enforce contracts" language to include
the "termination of contracts and the enjoyment of all benefits,
privileges, terms, and conditions of the contractual relationship,"
1981(b).In Rivers v. Roadway Express, Inc., 511 U.S. 298, this
Court held that the amendment enlarged the category of conduct subject
to 1981 liability, id., at 303, and thus did not apply to a case that
arose before it was enacted, id., at 300. Rivers reasoning supports
the conclusion that the 1991 Act qualifies as an "Act of Congress
enacted after [December 1, 1990]." Petitioners causes of action
clearly arose under the 1991 Act, and the hypothetical problems
posited by respondent and the Seventh Circuit pale in comparison with
the difficulties that federal courts faced for decades in trying to
answer questions raised by borrowing state limitations rules.
Pp. 1315.
305 F.3d 717, reversed and remanded.
Stevens, J., delivered the opinion for a unanimous Court.
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