Jones v. R. R. Donnelley & Sons Co.
541 U.S. 369, 2004 U.S. LEXIS 3236, 158 L. Ed. 2d 645 (2004)
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Rule of Law:
A cause of action arises under an Act of Congress enacted after December 1, 1990, and is governed by the four-year federal catch-all statute of limitations in 28 U.S.C. § 1658, if the plaintiff's claim was made possible by that post-1990 legislative enactment, regardless of whether the enactment amended a pre-existing statute.
Facts:
- Petitioners are African-American former employees of respondent R. R. Donnelley & Sons Co.'s manufacturing plant.
- During their employment, petitioners alleged they were subjected to a racially hostile work environment and given inferior employee status.
- Petitioners also claimed they were wrongfully terminated or denied transfers in connection with the closing of the plant.
- The alleged discriminatory conduct, including harassment and termination, occurred after the formation of their employment contracts.
- Prior to 1991, the Supreme Court's decision in Patterson v. McLean Credit Union held that 42 U.S.C. § 1981 did not cover post-contract formation conduct like racial harassment.
- In 1991, Congress enacted the Civil Rights Act of 1991, which amended § 1981 to explicitly cover post-contract formation discrimination, including termination and the terms and conditions of employment.
- Petitioners' claims were based on the new rights created by the 1991 amendment to § 1981.
Procedural Posture:
- Petitioners filed a class action lawsuit against their former employer, R. R. Donnelley & Sons Co., in the U.S. District Court for the Northern District of Illinois.
- The respondent moved for summary judgment, arguing the claims were barred by Illinois's two-year personal injury statute of limitations.
- The District Court denied the motion, ruling that the claims arose under the Civil Rights Act of 1991 and were therefore governed by the four-year federal catch-all statute of limitations, § 1658.
- The District Court certified its ruling for an interlocutory appeal.
- On appeal, the U.S. Court of Appeals for the Seventh Circuit reversed, holding that § 1658 applies only to causes of action created by entirely new statutes, not to amendments of pre-existing ones.
- The U.S. Supreme Court granted certiorari to resolve a circuit split on the issue.
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Issue:
Does the four-year federal catch-all statute of limitations, 28 U.S.C. § 1658, apply to claims, such as racial harassment and wrongful termination, that are made actionable by the Civil Rights Act of 1991, which amended the pre-existing 42 U.S.C. § 1981?
Opinions:
Majority - Justice Stevens
Yes. A cause of action 'arises under' a post-1990 Act for purposes of § 1658 if the plaintiff's claim was made possible by that Act. The Court reasoned that the phrase 'arising under' in § 1658 is ambiguous, so it must be interpreted in light of the statute's purpose. Congress enacted § 1658 to eliminate the uncertainty and litigation caused by the practice of 'borrowing' various state statutes of limitations for federal claims that lacked their own. A narrow interpretation that restricts § 1658 to entirely new, stand-alone statutes would subvert this purpose, as Congress frequently creates new rights by amending existing laws. The dispositive factor is the substantive effect of the new law—the creation of a new right to sue—not the legislative format. Because the petitioners' claims for hostile work environment and wrongful termination were not actionable under § 1981 until Congress amended it in 1991, their claims were made possible by, and thus 'arose under,' the 1991 Act, making the four-year federal limitations period applicable.
Analysis:
This decision clarifies and broadens the application of the federal catch-all statute of limitations, 28 U.S.C. § 1658. By holding that a claim 'arises under' a post-1990 act if the claim was 'made possible' by it, the Court established a functional and substantive test over a formalistic one. This promotes nationwide uniformity and predictability for civil rights claims and any other federal causes of action created through amendments to older statutes. The ruling significantly reduces the need for federal courts to engage in the complex and often inconsistent analysis of borrowing analogous state statutes of limitations, thereby fulfilling Congress's intent to simplify this area of law.
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