Reynoldsville Casket Co. v. Hyde

Background

A woman, Carol Hyde, sued a truck driver and the truck owner after a 1984 crash in Ohio, filing in 1987. Ohio normally gives two years to sue for such injuries, but a state “tolling” rule paused that deadline for defendants who lived out of state, so her suit qualified as timely. Ten months after she sued, the Court in Bendix said that tolling rule violated the Commerce Clause.

Reasoning

The Court had to decide whether Ohio could keep applying the tolling rule to claims that arose before Bendix. Relying on the Supremacy Clause and this Court’s retroactivity rule explained in Harper, the majority concluded that Bendix’s constitutional ruling applies backward to pending cases. The Court rejected Ohio’s effort to treat its ruling as a “remedy” based on people’s reliance on old law. The opinion explained that other examples where relief was limited—tax cases, qualified immunity, and finality rules—are different and do not justify Ohio’s choice here. Because Hyde’s claim depended on the now-unconstitutional tolling law, the Ohio Supreme Court’s reinstatement could not stand, and the judgment was reversed.

Real world impact

This decision makes clear that state courts cannot preserve suits that rely solely on an invalid tolling rule; older accident claims that would be time-barred under the ordinary two-year rule can be dismissed. It also signals limits on using state “remedies” to avoid the effect of federal constitutional rulings.

Dissents or concurrances

Justice Scalia said the case did not really present a remedial question and the unconstitutional law must simply be ignored. Justice Kennedy agreed with reversal but warned that in rare cases reliance interests might still affect relief.