Raygor v. Regents of the University of Minnesota

Background

Two university employees filed age-discrimination charges with federal and state agencies and then sued their employer, the state university system, in federal court under both federal and Minnesota law. The federal court dismissed the case on the ground that the state has immunity from such federal suits, and the employees then refiled their state-law claims in state court after the limitations period had run. Minnesota courts disagreed about whether a federal statute that tolls (pauses) filing deadlines while related claims are in federal court applied to claims against a state that had not consented to suit.

Reasoning

The central question was whether the federal supplemental-jurisdiction tolling rule (§1367(d)) pauses state filing deadlines for claims against state agencies that never agreed to be sued in federal court. The Court said no. It explained that Congress must speak clearly to change the usual balance between federal power and state immunity. Because the tolling rule does not unmistakably say it applies to suits against nonconsenting states, and applying it would raise serious federalism doubts, the Court would not read the statute to extend deadlines in those cases. The Court also found the university did not consent to be sued in federal court here.

Real world impact

The decision means people who sued state agencies in federal court and then lose because of state immunity cannot rely on §1367(d) to get extra time to refile in state court. Workers bringing state discrimination claims against state universities or other nonconsenting state agencies are most directly affected; some claims that might otherwise survive will instead be time-barred.