Artis v. District of Columbia

Justia Summary

Artis filed a federal-court suit against the District of Columbia, alleging a federal employment discrimination claim and three allied claims under D.C. law; nearly two years remained on the statute of limitations for the D.C. claims. More than two years later, the district court rejected the federal claim and dismissed the D.C.-law claims under 28 U.S.C. 1367(c). Artis refiled those claims in the D.C. Superior Court 59 days later. That court dismissed them as time-barred. The D.C. Court of Appeals affirmed. The Supreme Court reversed. Section 1367(d) provides that the “period of limitations for” refiling in state court a state claim “shall be tolled while the claim is pending [in federal court] and for a period of 30 days after it is dismissed unless State law provides for a longer tolling period.” The Court rejected an argument that the section merely provides a grace period, permitting the statute of limitations to run while the claim is pending in another forum and averting the risk of a time bar by according the plaintiff a fixed period in which to refile. Considering the ordinary meaning of the statutory language, the section is a tolling provision. It suspends the statute of limitations both while the claim is pending in federal court and for 30 days post-dismissal. The stop-the-clock interpretation of section1367(d) does not present a serious constitutional problem.