North Star Steel Co. v. Thomas
Headline: WARN worker-notice lawsuits are governed by state time limits, the Court held, letting different states set filing deadlines and affecting when employees or unions can sue employers.
Holding: Because WARN contains no deadline, the Court held that courts should borrow state time limits to determine when employees or unions must file WARN lawsuits, unless a state limit would frustrate the federal law’s purpose.
- Leaves WARN filing deadlines to each State’s time limits.
- Allows different States to set varied deadlines, affecting when workers can sue.
- May encourage plaintiffs to choose courts based on more favorable deadlines.
Summary
Background
The cases involve workers and unions who sued their employers under the Worker Adjustment and Retraining Notification Act (WARN), which requires covered employers to give 60 days notice before a plant closing or mass layoff. One suit was brought by a union over layoffs at a Georgia plant; another was brought by former nonunion employees over layoffs at a Pennsylvania plant. Both cases were filed in federal court in Pennsylvania, and the courts asked which rules should set the deadline for bringing a WARN suit.
Reasoning
The Court addressed whether the time limit for WARN lawsuits should come from state law or from a federal analogue. Because WARN does not include its own filing deadline, the Court followed its longstanding practice of borrowing a state statute of limitations unless the state rule would frustrate the federal law’s purpose. The Court found several Pennsylvania state periods (ranging from two to six years) that could apply and concluded none would undermine WARN. The Court therefore affirmed the Third Circuit’s choice to use state law rather than a uniform federal rule.
Real world impact
The decision means that when a federal law like WARN lacks a deadline, courts will generally look to the relevant State’s filing rules. That makes deadlines for WARN suits vary by State, may encourage plaintiffs to select forums with favorable time limits, and affects when employees or unions must act to preserve claims. The opinion also notes that statutes enacted after December 1, 1990, generally carry a four-year federal rule, which does not apply here.
Dissents or concurrances
Justice Scalia agreed with the outcome and stressed that state time limits should control, or, if necessary, no limit at all when state rules would frustrate the federal purpose.
Opinions in this case:
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