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:
National Federation of Independent Business v. Sebelius, 567 U.S. 519 (2012), is a landmark United States Supreme Court decision in which the Court upheld Congress's power to enact most provisions of the Patient Protection and Affordable Care Act (ACA), commonly called Obamacare, and the Health Care and Education Reconciliation Act (HCERA), including a requirement for most Americans to pay a penalty for forgoing health insurance by 2014. The Acts represented a major set of changes to the American health care system that had been the subject of highly contentious debate, largely divided on political party lines.
Arkansas Game and Fish Commission v. United States, 568 U.S. 23 (2012), is a decision by the Supreme Court of the United States holding that it was possible for government-induced, temporary flooding to constitute a "taking" of property under the Fifth Amendment to the U.S. Constitution, such that compensation could be owed to the owner of the flooded property.
Atlantic Marine Construction Co., Inc. v. United States District Court for the Western District of Texas, 571 U.S. 49 (2013), was a United States Supreme Court decision dealing with the enforcement of forum selection clauses.
Petrella v. Metro-Goldwyn-Mayer, Inc., 572 U.S. 663 (2014), is a United States Supreme Court copyright decision in which the Court held 6-3 that the equitable defense of laches is not available to copyright defendants in claims for damages.
Rodriguez v. United States, 575 U.S. 348 (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.
Davis v. Ayala, 576 U.S. 257 (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.
FERC v. Electric Power Supply Ass'n, 577 U.S. 260 (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. 108 (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. 411 (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.
Bank Markazi v. Peterson, 578 U.S. 212 (2016), was a United States Supreme Court case that found that a law which only applied to a specific case, identified by docket number, and eliminated all of the defenses one party had raised does not violate the separation of powers in the United States Constitution between the legislative (Congress) and judicial branches of government. The plaintiffs, in the case had initially obtained judgments against Iran for its role in supporting state-sponsored terrorism, particularly the 1983 Beirut barracks bombings and 1996 Khobar Towers bombing, and sought execution against a bank account in New York held, through European intermediaries, on behalf of Bank Markazi, the Central Bank of the Islamic Republic of Iran. The plaintiffs obtained court orders preventing the transfer of funds from the account in 2008 and initiated their lawsuit in 2010. Bank Markazi raised several defenses, including that the account was not an asset of the bank, but rather an asset of its European intermediary, under both New York state property law and §201(a) of the Terrorism Risk Insurance Act. In response to concerns that existing laws were insufficient for the account to be used to settle the judgments, Congress added an amendment to a 2012 bill, codified after enactment as 22 U.S.C. § 8772, that identified the pending lawsuit by docket number, applied only to the assets in the identified case, and effectively abrogated every legal basis available to Bank Markazi to prevent the plaintiffs from executing their claims against the account. Bank Markazi then argued that § 8772 was an unconstitutional breach of the separation of power between the legislative and judicial branches of government, because it effectively directed a particular result in a single case without changing the generally applicable law. The United States District Court for the Southern District of New York and, on appeal, the United States Court of Appeals for the Second Circuit both upheld the constitutionality of § 8772 and cleared the way for the plaintiffs to execute their judgments against the account, which held about $1.75 billion in cash.
Reyes Mata v. Lynch, 576 U.S. 143 (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."
Sturgeon v. Frost refers to two cases heard by the Supreme Court of the United States, both of which deal with the regulatory authority of the National Park Service over lands in Alaska under the Alaska National Interest Lands Conservation Act (ANILCA). In the first case, Sturgeon v. Frost I, 577 U.S. ___ (2016), the Court ruled that the National Park Service may regulate only "public" lands in Alaska and remanded the case to the Ninth Circuit Appeals Court to decide whether the river in question, which is "submerged land," is "public" or "non-public" land. In Sturgeon v. Frost II, 587 U.S. ___ (2019), the Court unanimously ruled that the ANILCA defines navigable waters in Alaska as "non-public" lands and that they are exempt from the National Park Service's national regulations.
Rotkiske v. Klemm, 589 U.S. ___ (2019), was a decision by the Supreme Court of the United States involving the statute of limitations under the Fair Debt Collection Practices Act of 1977. The Court ruled that the statute of limitations begins one year after the alleged FDCPA violation took place, not one year after the violation was discovered by the plaintiff. This ruling affirmed a decision by the 3rd Circuit Court of Appeals. It is noteworthy for being the first signed opinion released from the 2019 term. It is also noteworthy for resolving a circuit split regarding a major consumer protection law.
Garland v. Gonzalez, 596 U.S. ___ (2022), was a United States Supreme Court case related to immigration detention.
Arellano v. McDonough, 598 U. S. 1 (2023), is a United States Supreme Court case in which the Court held that 38 U.S.C. § 5110(b)(1), a provision relating to VA disability compensations, is not subject to equitable tolling.
