Artis v. District of Columbia

Background

Stephanie Artis, a District of Columbia health inspector, filed a federal employment-discrimination suit and three related D.C. claims in federal court. The federal court dismissed her federal claim and declined to keep the state claims. Artis refiled those state claims 59 days after dismissal in D.C. Superior Court, which held them time barred. The D.C. Court of Appeals read the federal statute, 28 U.S.C. §1367(d), to give only a 30-day grace period after dismissal.

Reasoning

The Supreme Court considered whether “tolled” in §1367(d) means “stop the clock” while the state claim is pending in federal court, or instead means only a 30-day grace period after dismissal. The Court held “tolled” means suspended—the limitations clock stops while the state claim is in federal court and resumes after dismissal, with an extra 30 days. The opinion relied on ordinary meaning, grammar (the object “period of limitations”), examples of other statutes, and rejected the idea that Congress silently adopted only a 30-day grace rule. The Court also rejected constitutional objections, saying the stop-the-clock rule serves federal-court administration and is consistent with Congress’ powers.

Real world impact

The ruling makes it easier for people who bring related federal and state claims to preserve their state claims without filing duplicate suits in state court. Plaintiffs who timely filed in federal court get the time they had left when they filed plus 30 days after dismissal; States may still provide longer tolling under their laws.

Dissents or concurrances

Justice Gorsuch dissented, arguing the statute can reasonably be read as a short grace period rooted in historical “journey’s account” practice and warning the Court’s reading unduly displaces state choices about limitation periods and raises federalism concerns.