Greyhound Lines, Inc. v. Melody Wilhite
Headline: Court declines review of dispute over applying a shorter labor lawsuit deadline retroactively, leaving the Ninth Circuit’s rule that avoids shortening filing time unchanged and circuit conflicts unresolved.
Holding: The Supreme Court declined to review the Ninth Circuit’s ruling that DelCostello should not be applied retroactively when doing so would shorten the filing deadline, leaving that circuit’s rule in place.
- Leaves Ninth Circuit rule blocking retroactive shortening of filing deadlines in place.
- Keeps conflicting rules across federal appeals courts, causing uncertainty for labor lawsuit timing.
- Parties must follow their circuit’s current rule unless the Court later reviews the issue.
Summary
Background
The case involves Greyhound Lines, Inc. and Melody Wilhite, a company and an individual in a dispute about how a recent rule should affect the deadline for certain labor-related lawsuits. The Ninth Circuit held that the DelCostello decision — which tied some union-related lawsuits to a six-month filing deadline — should not be applied retroactively when doing so would make the filing deadline shorter.
Reasoning
The core question was whether the DelCostello rule should apply to past cases in a way that changes how long people had to file claims. The Ninth Circuit relied on the Chevron Oil Co. v. Huson factors to decide that cutting short the filing period by applying the new rule retroactively would be unfair, so it refused retroactive application. Other federal appeals courts reached different results, some applying DelCostello retroactively and others saying the Huson analysis wasn’t required. The Supreme Court declined to review the conflict, leaving the Ninth Circuit’s approach intact.
Real world impact
For people and employers involved in these kinds of labor lawsuits, the denial means filing deadlines will depend on which federal appeals court governs a case. The decision does not settle the nationwide disagreement; it simply leaves the split among circuits in place. Because the Supreme Court did not take the case, the rule could change later if the Court agrees to decide the issue.
Dissents or concurrances
Justice White dissented from the denial of review and said the Court should grant review to resolve the conflicting rulings among the appeals courts.
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