Chardon v. Fumero Soto

1983-06-20

Headline: Class-action timing clarified: Court upholds Puerto Rico rule letting unnamed demoted school employees get a new one‑year filing period after class denial, not a mere suspension, affecting civil‑rights deadlines.

Holding: The Court held that when state law governs civil‑rights time limits, Puerto Rico’s rule applies and unnamed class members receive a full new one‑year period after class certification is denied, rather than just a suspension.

Real World Impact:

Lets unnamed class members gain a new state-based filing period after class denial.
Makes civil-rights filing deadlines depend on local state tolling rules.
Changes how lawyers calculate deadlines for federal civil‑rights claims.

Topics: class actions, statute of limitations, civil rights, court procedure

Summary

Background

Puerto Rican school officials demoted 36 nontenured supervisors because of their political views. A class action was filed on June 19, 1978, just before Puerto Rico’s one‑year filing deadline, but the district court denied class certification on August 21, 1978. The unnamed class members later filed individual federal civil‑rights suits more than one year after their claims accrued but less than one year after the class denial.

Reasoning

The Court confronted whether the tolling caused by the earlier class action meant the one‑year clock was merely suspended or whether a new one‑year period began to run after class denial. Because §1983 claims borrow state limitation rules under 42 U.S.C. §1988 when no federal statute applies, the Court held that state law governs both tolling and its effect. It affirmed the First Circuit’s reading of Puerto Rican law, which treats tolling as creating a new limitations period after tolling ends, and concluded that American Pipe did not create a nationwide federal rule requiring suspension in §1983 cases.

Real world impact

The ruling means unnamed class members in civil‑rights class actions governed by state law may get a fresh filing period if their state applies a renewal rule. Timing for individual filings therefore depends on local law, and this procedural ruling affects how lawyers and courts calculate deadlines in similar cases.

Dissents or concurrances

Justice Rehnquist dissented, arguing American Pipe established a federal Rule 23 tolling rule that suspends limitations, and he warned the majority’s approach creates uncertainty and extra litigation.