Menominee Tribe of Wis. v. United States

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Menominee Tribe of Wisconsin v. United States
Seal of the United States Supreme Court.svg
Argued December 1, 2015
Decided January 25, 2016
Full case nameMenominee Indian Tribe of Wisconsin, Petitioner v. United States
Docket nos. 14–510
Citations577 U.S. ___ ( more )
136 S. Ct. 750; 193 L. Ed. 2d 652
Prior historySummary judgment granted, 841 F. Supp. 2d 99 (D.D.C. 2012); affirmed, 764 F.3d 51 (D.C. Cir. 2014); cert. granted, 135 S. Ct. 2927 (2015).
Holding
Plaintiff was not entitled to equitable tolling because they did not demonstrate "extraordinary circumstances"
Court membership
Chief Justice
John Roberts
Associate Justices
Antonin Scalia  · Anthony Kennedy
Clarence Thomas  · Ruth Bader Ginsburg
Stephen Breyer  · Samuel Alito
Sonia Sotomayor  · Elena Kagan
Case opinions
MajorityAlito, joined by unanimous
Laws applied
Contract Disputes Act of 1978, 41 U.S.C. § 7101 et seq.,

Menominee Tribe of Wis. v. United States, 577 U.S. ___ (2016), was a case in which the Supreme Court of the United States clarified when litigants are entitled to equitable tolling of a statute of limitations. [1] In a unanimous opinion written by Justice Samuel Alito, the Court held that the plaintiff in this case was not entitled to equitable tolling of the statute of limitations because they did not demonstrate that "extraordinary circumstances" prevented the timely filing of the lawsuit. [2]

Supreme Court of the United States Highest court in the United States

The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. Established pursuant to Article III of the U.S. Constitution in 1789, it has original jurisdiction over a narrow range of cases, including suits between two or more states and those involving ambassadors. It also has ultimate appellate jurisdiction over all federal court and state court cases that involve a point of federal constitutional or statutory law. The Court has the power of judicial review, the ability to invalidate a statute for violating a provision of the Constitution or an executive act for being unlawful. However, it may act only within the context of a case in an area of law over which it has jurisdiction. The court may decide cases having political overtones, but it has ruled that it does not have power to decide nonjusticiable political questions. Each year it agrees to hear about one hundred to one hundred fifty of the more than seven thousand cases that it is asked to review.

Samuel Alito Associate Justice of the Supreme Court of the United States

Samuel Anthony Alito Jr. is an Associate Justice of the Supreme Court of the United States. He was nominated by President George W. Bush and has served since January 31, 2006.

Contents

Background

This case began as a contract dispute between the Menominee Tribe of Wisconsin and the federal government where the tribe alleged that the federal government failed to adequately fund aid programs under the Indian Self-Determination and Education Assistance Act of 1975. [3] The federal government argued that the Tribe should not have been allowed to bring their claims because they were not filed within the Contract Disputes Act's [4] six-year statute of limitations. [5] The Tribe, on the other hand, argued that the statute of limitations should be equitably tolled because a similar class action suit was pending for 707 days before the Tribe filed suit. [6] The United States District Court for the District of Columbia ruled that the Tribe was not entitled to equitable tolling because they did not demonstrate "extraordinary circumstances", which are a prerequisite for a claim for equitable tolling. [7] On appeal, the United States Court of Appeals for the District of Columbia Circuit affirmed the district court's ruling, and the Supreme Court of the United States ultimately granted certiorari to resolve a circuit split about the circumstances under which litigants are entitled to equitable tolling. [8] [upper-alpha 1]

Menominee Indian tribe in Wisconsin, USA

The Menominee are a federally recognized nation of Native Americans, with a 353.894 sq mi (916.581 km2) reservation in Wisconsin. Their historic territory originally included an estimated 10 million acres (40,000 km2) in present-day Wisconsin and the Upper Peninsula of Michigan. The tribe currently has about 8,700 members.

Federal government of the United States National government of the United States

The Federal Government of the United States is the national government of the United States, a federal republic in North America, composed of 50 states, a federal district, five major self-governing territories, and several island possessions. The federal government is composed of three distinct branches: legislative, executive, and judicial, whose powers are vested by the U.S. Constitution in the Congress, the President, and the federal courts, respectively. The powers and duties of these branches are further defined by acts of congress, including the creation of executive departments and courts inferior to the Supreme Court.

Indian Self-Determination and Education Assistance Act of 1975 United States law

The Indian Self-Determination and Education Assistance Act of 1975 authorized the Secretary of the Interior, the Secretary of Health, Education, and Welfare, and some other government agencies to enter into contracts with, and make grants directly to, federally recognized Indian tribes. The tribes would have authority for how they administered the funds, which gave them greater control over their welfare. The ISDEAA is codified at Title 25, United States Code, beginning at section 5301.

Opinion of the Court

In a unanimous opinion written by Justice Samuel Alito, the Court held that the tribe was not entitled to equitable tolling of the statute of limitations. [11] Citing Holland v. Florida , [12] Justice Alito reaffirmed that litigants are only entitled to equitable tolling if they diligently pursue their claims and that "extraordinary circumstances" prevented timely filing. [13] Citing Pace v. DiGuglielmo, [14] Justice Alito also reaffirmed that these two factors are "elements" that should be considered together, and that they are "not merely factors of indeterminate or commensurable weight." [15] Justice Alito held that the tribe did not demonstrate extraordinary circumstances in this case, and was therefore not entitled to equitable tolling. [16]

Holland v. Florida, 560 U.S. 631 (2010), was a United States Supreme Court case in which the Court held that the statute of limitations under the Antiterrorism and Effective Death Penalty Act is subject to equitable tolling in appropriate cases.

Commentary and analysis

In his review of the case for SCOTUSblog , Ronald Mann observed that "the case is likely to cast a shadow over equitable tolling cases for years to come" and suggested that "[f]uture Indian tribes with similar problems may well wish that the tribe in this case had accepted its defeat at the court of appeals without pushing for such a stern limitation on the doctrine from the Supreme Court itself." [17]

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SCOTUSblog is a law blog written by lawyers, law professors, and law students about the Supreme Court of the United States. The blog was formerly sponsored by Bloomberg Law. The site tracks cases before the Court from the certiorari stage through the merits stage. The site live blogs as the Court announces opinions and grants cases, and sometimes has information on the Court's actions published before either the Court or any other news source does. The site frequently hosts symposiums with leading experts on the cases before the Court. The site comprehensively covers all of the cases argued before the Court and maintains an archive of the briefing and other documents in each case.

See also

The following is a complete list of cases decided by the United States Supreme Court organized by volume of the United States Reports in which they appear. This is a list of volumes of U.S. Reports, and the links point to the contents of each individual volume.

Notes

  1. ↑ The Supreme Court noted that the District of Columbia Circuit's opinion created a split with the United States Court of Appeals for the Federal Circuit, which permitted equitable tolling "under similar circumstances" in Arctic Slope Native Assn., Ltd. v. Sebelius, [9] which was another "tribal entity equitable tolling" case. [10]

Related Research Articles

Tolling is a legal doctrine that allows for the pausing or delaying of the running of the period of time set forth by a statute of limitations, such that a lawsuit may potentially be filed even after the statute of limitations has run. Although grounds for tolling the statute of limitations vary by jurisdiction, common grounds include:

County of Oneida v. Oneida Indian Nation of New York State, 470 U.S. 226 (1985), was a landmark United States Supreme Court case concerning aboriginal title in the United States. The case, sometimes referred to as Oneida II, was "the first Indian land claim case won on the basis of the Nonintercourse Act."

Atlantic Marine Construction Co., Inc. v. United States District Court for the Western District of Texas, 571 U.S. 49 (2013), was United States Supreme Court decision dealing with the enforcement of forum selection clauses.

Rodriguez v. United States, 575 U.S. ___ (2015), was a United States Supreme Court case which analyzed whether police officers may extend the length of a traffic stop to conduct a search with a trained detection dog. In a 6–3 opinion, the Court held that officers may not extend the length of a traffic stop to conduct a dog sniff unrelated to the original purpose of the stop. However, the Court remanded the case to the United States Court of Appeals for the Eighth Circuit to determine whether the officer's extension of the traffic stop was independently justified by reasonable suspicion. Some analysts have suggested that the Court's decision to limit police authority was influenced by ongoing protests in Ferguson, Missouri.

Texas Dept. of Housing and Community Affairs v. Inclusive Communities Project, Inc., 576 U.S. ___ (2015), was a United States Supreme Court case in which the Court analyzed whether disparate impact claims are cognizable under the Fair Housing Act. In Justice Anthony Kennedy's majority opinion, the Court held that Congress specifically intended to include disparate impact claims in the Fair Housing Act, but that such claims require a plaintiff to prove it is the defendant's policies that cause a disparity.

Davis v. Ayala, 576 U.S. ___ (2015), was a case in which the Supreme Court of the United States upheld a death sentence of a Hispanic defendant despite the fact that all Blacks and Hispanics were rejected from the jury during the defendant's trial. The case involved a habeas corpus petition submitted by Hector Ayala, who was arrested and tried in the late 1980s for the alleged murder of three individuals during an attempted robbery of an automobile body shop in San Diego, California in April 1985. At trial, the prosecution used peremptory challenges to strike all Black and Hispanic jurors who were available for jury service. The trial court judge allowed the prosecution to explain the basis for the peremptory challenges outside the presence of Ayala's counsel, "so as not to disclose trial strategy". Ayala was ultimately sentenced to death, but he filed several appeals challenging the constitutionality of the trial court's decision to exclude his counsel from the hearings.

Mullenix v. Luna, 577 U.S. ___ (2015), was a case in which the Supreme Court of the United States held that a police officer who shot a suspect during a police pursuit was entitled to qualified immunity. In a per curiam opinion, the Court held that prior precedent did not establish "beyond debate" that the officer's actions were objectively unreasonable.

FERC v. Electric Power Supply Ass'n, 577 U.S. ___ (2016), was a case in which the Supreme Court of the United States held that the Federal Energy Regulatory Commission had the authority to regulate demand response transactions. Justice Scalia's dissenting opinion in this case was the last opinion he wrote before his death in February 2016.

Kansas v. Carr, 577 U.S. ___ (2016), was a case in which the Supreme Court of the United States clarified several procedures for sentencing defendants in capital cases. Specifically, the Court held that judges are not required to affirmatively instruct juries about the burden of proof for establishing mitigating evidence, and that joint trials of capital defendants "are often preferable when the joined defendants’ criminal conduct arises out of a single chain of events". This case included the last majority opinion written by Justice Antonin Scalia before his death in February 2016.

Montanile v. Board of Trustees of the National Elevator Industry Health Benefit Plan, 577 U.S. ___ (2016) was a case in which the Supreme Court of the United States clarified subrogation procedures under the Employee Retirement Income Security Act ("ERISA"). The Court held that healthcare plan fiduciaries cannot demand reimbursement for medical benefits from a plan member's general assets if the beneficiary's general assets cannot be traced back to the original payment from the fiduciary. Although some scholars suggested that the court's ruling would have little impact, others suggested the case places "significant restrictions" on the rights of ERISA benefit plan providers.

Caetano v. Massachusetts, 577 U.S. ___ (2016), was a case in which the Supreme Court of the United States unanimously vacated a Massachusetts conviction of a woman who carried a stun gun for self-defense.

Reyes Mata v. Lynch, 576 U.S. ___ (2015), is a United States Supreme Court case in which the Court ruled that the federal courts of appeals have jurisdiction to review the orders of the Board of Immigration Appeals to reject motions to reopen.

Ocasio v. United States, 578 U.S. ___ (2016), was a United States Supreme Court case in which the Court clarified whether the Hobbs Act's definition of conspiracy to commit extortion only includes attempts to acquire property from someone who is not a member of the conspiracy. The case arose when Samuel Ocasio, a former Baltimore, Maryland police officer, was indicted for participating in a kickback scheme with an automobile repair shop where officers would refer drivers of damaged vehicles to the shop in exchange for cash payments. Ocasio argued that he should not be found guilty of conspiring to commit extortion because the only property that was exchanged in the scheme was transferred from one member of the conspiracy to another, and an individual cannot be found guilty of conspiring to extort a co-conspirator.

Musacchio v. United States, 577 U.S. ___ (2016), was a case in which the Supreme Court of the United States clarified procedures for appellate review when the government does not object to an erroneous jury instruction that adds elements to a criminal offense as well as whether a defendant may raise a statute of limitations defense for the first time on appeal. In a unanimous opinion written by Justice Clarence Thomas, the Court held that when reviewing a claim that the government failed to demonstrate sufficient evidence to substantiate a criminal offense, an appellate court should assess the elements of the alleged crime, rather than the elements that were described in jury instructions. Justice Thomas explained that "[a] reviewing court’s limited determination on sufficiency review ... does not rest on how the jury was instructed." Additionally, with respect to the statute of limitations issue, Justice Thomas held that a statute of limitations defense cannot be raised for the first time on appeal.

Americold Realty Trust v. ConAgra Foods, Inc., 577 U.S. ___ (2016), was a case in which the Supreme Court of the United States clarified rules for determining whether a federal court may exercise diversity jurisdiction in cases involving unincorporated organizations. The case began as a contract dispute between food producers and a warehouse owner when millions of tons of stored food were destroyed in a warehouse fire. A federal trial court initially ruled in favor of the warehouse owner, but on appeal, the United States Court of Appeals for the Tenth Circuit ruled that the federal district court may not have had jurisdiction. The Tenth Circuit held that the warehouse owner, a real estate investment trust ("REIT"), should be treated as an unincorporated organization and the district court should not be allowed to exercise diversity jurisdiction without examining the citizenship of the members of the real estate investment trust. The warehouse owner appealed to the Supreme Court, which granted certiorari to resolve a circuit split "regarding the citizenship of unincorporated entities."

Army Corps of Engineers v. Hawkes Co., 578 U.S. ___ (2016), was a case in which the Supreme Court of the United States held that a Clean Water Act jurisdictional determination issued by the United States Army Corps of Engineers is reviewable under the Administrative Procedure Act because jurisdictional determinations constitute "final agency action".

Manuel v. Joliet, 580 U.S. ___ (2017), was a case in which the United States Supreme Court held that a criminal defendant may bring a claim under the Fourth Amendment of the United States Constitution to challenge pretrial confinement. In a 6-2 majority opinion written by Justice Elena Kagan, the Court stated that "the Fourth Amendment governs a claim for unlawful pretrial detention even beyond the start of legal process". This decision reversed and remanded the judgment of the Seventh Circuit Court of Appeals. Justice Clarence Thomas wrote a dissenting opinion. Justice Thomas also joined a dissenting opinion by Justice Samuel Alito.

Life Technologies Corp. v. Promega Corp., 580 U.S. ___ (2017), was a case in which the United States Supreme Court clarified the application of the Patent Act of 1952 to the sale of components of patented inventions in foreign markets. In an opinion written by Associate Justice Sonia Sotomayor, the Court held that the sale of a "single component" in a foreign market "does not constitute a substantial portion of the components that can give rise to liability under [the Patent Act of 1952]." Justice Samuel Alito wrote an opinion concurring in part and concurring in the judgment, in which he was joined Justice Clarence Thomas. Chief Justice John Roberts took no part in the decision of the case.

Kellogg Brown & Root Services, Inc. v. United States ex rel. Carter, 575 U.S. ___ (2015), was a United States Supreme Court involving KBR and a former KRB contractor, Benjamin Carter. In a unanimous opinion written by Associate Justice Samuel Alito, the Court held that Wartime Suspension of Limitations Act only applies to criminal offenses. The Court also held that qui tam lawsuits filed under the False Claims Act are no longer considered "pending" after they have been dismissed.

Washington State Dep't of Licensing v. Cougar Den, Inc., 586 U.S. ___ (2019), was a United States Supreme Court case in which the Court held that the Yakama Nation Treaty of 1855 preempts the state law which the State purported to be able to tax fuel purchased by a tribal corporation for sale to tribal members. This was a 5-4 plurality decision, with Justice Breyer's opinion being joined by Justices Sotomayor and Kagan. Justice Gorsuch, joined by Justice Ginsburg, penned a concurring opinion. There were dissenting opinions by Chief Justice Roberts and Justice Kavanaugh.

References

  1. ↑ Menominee Tribe of Wis. v. United States,No. 14-510 , 577 U.S. ___, slip op. at 1, 3–4, 5–8 (2016).
  2. ↑ Menominee Tribe of Wis., slip op. at 1, 5–9.
  3. ↑ Menominee Tribe of Wis., slip op. at 1–2 (citing Indian Self-Determination and Education Assistance Act, Pub. L. 93–638, 88 Stat. 2203, 25 U.S.C. § 450 et seq.
  4. ↑ 41 U.S.C. § 7101 et seq.
  5. ↑ Menominee Tribe of Wis., slip op. at 2–4.
  6. ↑ Menominee Tribe of Wis., slip op. at 3–4.
  7. ↑ Menominee Tribe of Wis., slip op. at 4 (citing 841 F. Supp. 2d 99 (D.D.C. 2012)).
  8. ↑ Menominee Tribe of Wis., slip op. at 4–5 (citing 764 F.3d 51 (D.C. Cir. 2014)).
  9. ↑ Arctic Slope Native Assn., Ltd. v. Sebelius, 699F.3d1289 (Fed. Cir. 2012).
  10. ↑ Menominee Tribe of Wis., slip op. at 5.
  11. ↑ Menominee Tribe of Wis., slip op. at 5–9.
  12. ↑ Holland v. Florida , 560 U.S. 631, 649 (2010).
  13. ↑ Menominee Tribe of Wis., slip op. at 5 (internal citations and quotations omitted).
  14. ↑ Pace v. DiGuglielmo, 544 U.S. 408, 418 (2005).
  15. ↑ Menominee Tribe of Wis., slip op. at 5–6 (internal citations and quotations omitted).
  16. ↑ Menominee Tribe of Wis., slip op. at 7–9.
  17. ↑ Ronald Mann, Opinion analysis: Justices rebuff tribe’s claim for equitable tolling in government-contract dispute, SCOTUSblog (Jan. 25, 2016)
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