statute of limitations

Petitioner Calvin Smith was involved in a criminal drug distribution organization and imprisoned for a related murder in 1994. In 2000, a grand jury brought indictments against him. Smith defended his two conspiracy charges on the grounds that the statute of limitations barred his conviction because he had withdrawn from the conspiracy more than five years ago. The trial court directed the jury that the burden of proof was on Smith as defendant to prove withdrawal by a preponderance of the evidence. Smith claims his participation in the conspiracy during the statutory period is a necessary element of his crime that the government must prove. Additionally, since withdrawal and participation are mutually exclusive, his withdrawal would negate an essential element of the government's case against him. The United States argues that withdrawal is an affirmative defense, and the burden of proof lies with the defendant. This case will define the boundaries of Due Process Protection in conspiracy cases and similar cases involving amorphous and on-going criminal activity.

Questions as Framed for the Court by the Parties

Written by

Edited by

Issues

This case asks the Supreme Court to clarify the procedures used when granting combat-related special compensation (“CRSC”)—specifically, whether the statute enacting CRSC also provides a settlement mechanism. Generally, military-related claims are governed by the Barring Act, which has a six-year statute of limitations. Soto argues that the Barring Act does not apply here because the CRSC-enacting statute provides its own mechanism for settling claims, thereby displacing the Barring Act. The United States instead asserts that the Barring Act is only displaced when a statute explicitly grants settlement authority, which is not granted in the CRSC statute, and that applying a different rule would be contrary to prior decisions. This case raises important questions regarding combat-wounded veterans’ access to compensation and the administrative and legal burden on the government. 

Questions as Framed for the Court by the Parties

Additional Resources

Issues

In this case, the Supreme Court will determine whether the ERISA’s six-year filing window prohibits a claim that 401(k) plan fiduciaries breached their duty of prudence by offering higher-cost mutual funds to plan participants, despite identical lower-cost mutual funds being available, when fiduciaries initially chose the higher-cost mutual funds more than six years before the claim was filed. A group of employee-beneficiaries argue that plan fiduciaries have an “ongoing” duty of prudence under ERISA and the failure to remove an imprudent investment gives rise to a new six-year period. Edison International, the employer, counters that case should be dismissed because the record does not reflect the question that the Court granted certiorari for; or, in the alternative, that the judgment below should be affirmed because there is no reversible error. The resolution of this case could have implications concerning the future cost of ERISA-governed benefits plan, and the scope of fiduciary duties.

Questions as Framed for the Court by the Parties

Written by

Edited by

Additional Resources

Issues

The Clintwood Elkhorn Mining Company sought to recover export tax payments after a federal court found the 1978 tax unconstitutional. Clintwood filed timely administrative refund claims under the IRS Tax Code within its three-year statute of limitations, and received repayments with interest for 1997 to 1999. However, Clintwood also filed an Export Clause damages claim for tax payments from 1994 to 1996 under the Tucker Act, which has a longer six-year statute of limitations. The government argued that the Tax Code provides the exclusive remedy for such refunds, while Clintwood argued that the Tucker Act alternative best remedies the government's unconstitutional taxation. The Court of Federal Claims found that Clintwood was entitled to receive damages, but not interest, under the Tucker Act. On appeal, the Federal Circuit awarded Clintwood both damages and interest for its 1994 to 1996 payments. The Supreme Court will determine whether Clintwood can file claims for repayment of unconstitutional taxes under the Tucker Act, and whether these alternative claims include interest awards. In addition to affecting the outcome of similar pending cases, the Court's decision will likely affect all taxpayers by determining the amount of reimbursement for taxes later found to be unconstitutional.

Questions as Framed for the Court by the Parties

Additional Resources

Issues

In 2006, the IRS adjusted Respondent Home Concrete’s 1999 tax return, claiming that Home Concrete overstated its basis in sold assets. The Fourth Circuit found that this adjustment was untimely under the general three year statute of limitations for IRS actions, concluding that overstatements of basis are not omissions that would trigger an extended six year statute of limitations. Petitioner, the United States, argues that the language and purpose behind the statute clarify that overstating a sold asset’s basis triggers the extended period, and that the Fourth Circuit should have deferred to the IRS's statutory interpretation contained within a Treasury Department regulation finalized during the appeal. Home Concrete argues that Supreme Court precedent applies here, eliminating ambiguity in the statutory interpretation. The Supreme Court’s decision will resolve a circuit split over the proper limitations period; the decision will also address the degree of deference due to a Treasury regulation that may be interpreted as conflicting with Supreme Court precedent, and that may be viewed as applying retroactively. The Court’s decision may affect the IRS’s timeframe to detect certain complex tax schemes, and the time period within which taxpayers are subject to audits.

Questions as Framed for the Court by the Parties

Written by

Edited by

Additional Resources

Issues

Andre Wallace was tried for and convicted of murder based on a confession obtained by Chicago detectives when he was fifteen years old. After several appeals, Wallace’s conviction was annulled by the Illinois Appellate Court, which held that Wallace was arrested without probable cause and that his unlawfully obtained confession could not be used to convict him of murder because it was not “sufficiently attenuated from his unlawful arrest.”  Wallace v. City of Chicago, 440 F.3d 421, 422 (7th Cir. 2006). Left with no other substantial evidence to convict Wallace, the prosecution dropped all charges against him. Wallace then sued the City of Chicago as well as Detectives Kristen Kato and Eugene Roy, under 42 U.S.C. § 1983, for violating his Fourth Amendment rights. The district court granted the detectives and the City of Chicago summary judgment on all of Wallace’s claims for his failure to meet the two-year statute of limitation. The Seventh Circuit affirmed the district court’s decision and found that “false arrest claims accrue at the time of the arrest,” rather than at the time the claimant’s conviction is overturned, concluding that Wallace’s claim was barred. Wallace v. City of Chicago, 440 F.3d at 423.  The Seventh Circuit majority and dissent indicate the existence of a conflict between circuit courts as to when the statute of limitations begins to run for damages claims resulting from false arrests.  The Supreme Court granted certiorari to resolve the conflict. The Supreme Court’s decision in this case will reflect its view on the correct balance between state interests, such as efficiency in the trial process, and the rights of individual defendants, such as having the opportunity to recover for damages arising from ? 1983 violations. Whether the statute of limitations begins to run at the time of arrest or at the time a conviction is overturned will influence when a claimant will be able to bring ? 1983 claims and may limit the availability of remedies for ? 1983 claims.

Questions as Framed for the Court by the Parties

Issues

This case asks the Supreme Court to decide whether a copyright plaintiff can recover damages for infringements over three years before the filing of a lawsuit if the plaintiff discovered or should have discovered the infringement within three years of the filing of the lawsuit. Petitioners Warner Chappell Music, Inc., and Artist Publishing Group, LLC, contend that the discovery rule, which provides that a claim accrues when plaintiff discovered or should have discovered the infringement, is inapplicable because the statute of limitations commences at the time of infringement, marking the completion of the cause of action. Additionally, Petitioners assert that applying the discovery rule would contravene Congress’s intent, as the language pertaining to the discovery rule is intentionally absent from the copyright provision. On the other hand, Respondents Nealy and Music Specialist, Inc. argue that Petitioners’ challenge on the discovery rule exceeds the scope of the issue presented to the Supreme Court, as the lower courts already presumed the application of the discovery rule in this case. Respondents also posit that introducing a separate damages bar—a cap on damages that can be awarded to a plaintiff—in federal copyright cases would undermine Congress’s purpose, as copyright law does not impose such a bar. This case will affect the scope of infringement cases initiated by copyright holders and alter the burden of proof for each party in future copyright cases.

Questions as Framed for the Court by the Parties

Additional Resources

Issues

This case asks the Supreme Court to determine if the Quiet Title Act’s statute of limitations is a jurisdictional requirement. Petitioners Larry Steven Wilkins and Jane B. Stanton argue that Congress must expressly state its intent when drafting a statute of limitations meant to be treated as a jurisdictional bar; therefore, the absence of such explicit language in the Quiet Title Act means that the statute of limitations is not jurisdictional. The United States contends that Supreme Court precedent supports treating the statute of limitations as a jurisdictional rule and emphasizes that there are no intervening Supreme Court decisions or statutory revisions of the Quiet Title Act that overrule such precedent. The outcome of this case will determine the accessibility of legal relief for individuals when resolving land disputes with the federal government and affect the balance between local governments and the federal government in litigation involving the Quiet Title Act.

Questions as Framed for the Court by the Parties

Additional Resources

Issues

Petitioner Patrick Wood filed a petition for writ of habeas corpus on February 25, 2008, in order to challenge his murder conviction. On appeal, the appellate court raised, sua sponte, a 28 U.S.C. § 2244(d) statute of limitations defense that barred Wood’s claims. Wood argues that appellate courts lack authority to raise a statute of limitations defense sua sponte, because an affirmative defense is forfeited if not raised, and because the government waived its statute of limitations defense at the district court level. In opposition, Kevin Milyard argues that appellate courts do have authority to raise a statute of limitations defense sua sponte, assuming the state did not intelligently waive the defense in the district court. In determining appellate court capacity to independently raise statute of limitations defenses, this decision will impact the finality of lower court decisions.

Questions as Framed for the Court by the Parties

Written by

Edited by

Additional Resources