Jones v. R. R. Donnelley & Sons Co.

Background

A group of African-American former employees of a Chicago manufacturing division filed a class action on November 25, 1996. They alleged a racially hostile work environment, inferior employee status, wrongful termination, and denial of transfers after a plant closing. The employer argued the claims were time-barred under Illinois law. The employees said the Civil Rights Act of 1991 changed 42 U.S.C. § 1981 so their claims are governed by the four-year federal limit in 28 U.S.C. § 1658. The District Court applied the four-year rule, the Court of Appeals disagreed, and the Supreme Court granted review to resolve a split in the federal courts.

Reasoning

The central question was whether a claim "arose under" the 1991 Act so that the four-year federal rule applies. Before 1991, the Court had held that § 1981 did not cover harassment after a contract was formed. Congress amended § 1981 in 1991 to include terminations and conditions of the contractual relationship, making some claims possible that previously were not. Looking at the purpose and history of § 1658 and the confusion caused by borrowing state time limits, the Court held that a cause of action "arises under" a post-1990 Act when the plaintiff’s claim was made possible by that enactment. Because the employees’ hostile-work-environment and termination claims depended on the 1991 amendment, the four-year federal limit applies. The Supreme Court reversed the Court of Appeals and remanded the case.

Real world impact

The ruling makes the four-year federal deadline available for claims created by post-1990 federal laws, reducing inconsistent state-by-state deadlines. It spares courts and litigants from choosing among different state limitation rules for many new federal causes of action while keeping older, pre-1990 claims under their borrowed state limits. The case returns the matter for further proceedings consistent with this rule.