Unexcelled Chemical Corp. v. United States
Headline: Court applies two-year Portal-to-Portal limit to Government suits for Walsh‑Healey child‑labor damages, starting the clock when minors were employed and potentially barring older claims.
Holding:
- Two‑year clock for government suits begins at the date minors were employed.
- Government may be barred from recovering Walsh‑Healey liquidated damages if suit delayed beyond two years.
- Filing an administrative complaint does not start or toll the two‑year limitation period.
Summary
Background
The United States sued to recover liquidated damages under the Walsh‑Healey Act after a Department of Labor complaint charged a contractor with knowingly employing minors during 1942–1945. The Secretary of Labor’s Hearing Examiner found liability on February 25, 1949, assessing $15,600 in liquidated damages. That decision became final after the contractor had a statutory twenty‑day review period. The Government filed suit on January 27, 1950. The contractor defended on the ground that §6 of the Portal‑to‑Portal Act imposes a two‑year statute of limitations that had expired.
Reasoning
The central question was when a cause of action “accrued” under §6 and whether the two‑year limit applies to Walsh‑Healey liquidated damages. The Court examined §6’s plain words and concluded that Congress included “liquidated damages” under the Walsh‑Healey Act. The Court rejected the contractor’s argument that the two‑year clock waits until administrative findings are final. Instead, the Court said a cause of action arises when the breach occurs — here, when the minors were employed — so the limitation period runs from that date. The Court reversed the Court of Appeals’ decision.
Real world impact
The ruling means the United States must bring suits to recover Walsh‑Healey liquidated damages within two years of the violating conduct. Administrative complaints and departmental proceedings do not, by themselves, preserve or start the two‑year period. If the Government waits longer, its claims may be time‑barred unless Congress changes the law. The decision resolves a circuit split about accrual timing for these government enforcement actions.
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