United States v. Lindsay
Headline: Ruling upholds dismissal of a seven‑year‑old federal claim, holding the six‑year time limit begins when the right arose, which lets older government claims not sued within six years be barred.
Holding:
- Allows older government claims to be time‑barred if not sued within six years of their creation.
- Makes businesses who dealt with the Commodity Credit Corporation lose claims older than six years.
- Leaves Congress able to change or protect older government claims through new laws.
Summary
Background
The United States sued Lindsay and others after they allegedly delivered damaged wool to a federal agency in 1945. The Government filed the suit in 1952. Defendants said the suit was too late because a 1948 law bars suits unless brought within six years after the right to sue "accrued." Lower courts dismissed the case, and different circuit courts had disagreed about what "accrued" means for claims that arose before the 1948 law.
Reasoning
The Court addressed whether a pre‑existing Government claim "accrued" when the right first came into existence (the 1945 delivery) or when the 1948 law took effect. The majority gave "accrued" its ordinary meaning — the date the right arose — and concluded applying the six‑year limit to older government claims does not raise a constitutional problem. The Court found no clear legislative history showing Congress intended a special meaning, and it affirmed the dismissal because the 1952 suit came after six years from 1945.
Real world impact
The decision means many older claims against the Commodity Credit Corporation or similar federal transactions can be time‑barred if not sued within six years of their creation. People and businesses who dealt with the agency may lose the chance to bring old claims unless Congress acts to revive or protect them. The Court left open separate questions about how the rule might apply to private parties.
Dissents or concurrances
Justice Reed dissented, arguing the statute should be read prospectively to avoid destroying valid pre‑existing claims and noting statements and precedents suggesting a different result.
Opinions in this case:
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