Nutraceutical Corp. v. Lambert

Background

A consumer, Troy Lambert, sued a company that sells dietary supplements and originally won permission to proceed as a class. On February 20, 2015, the district court decertified the class. Lambert told the district court on March 2 that he planned to ask for reconsideration and the court set a March 12 deadline; Lambert filed a reconsideration motion on March 12 and the court denied it on June 24. Fourteen days after that denial, Lambert asked the Ninth Circuit for permission to appeal the decertification order, but the company said the petition was too late under the 14-day rule in Federal Rule of Civil Procedure 23(f).

Reasoning

The central question was whether an appeals court can excuse a missed 14-day deadline for seeking permission to appeal a class-certification ruling. The Supreme Court agreed the rule is not a jurisdictional bar but held the text of the rules shows that courts may not use equitable tolling to forgive an untimely Rule 23(f) petition. The Court explained that other rules of appellate procedure specifically prevent extending or permitting late filings of this sort, and prior decisions interpreting similar rules support that conclusion. Because the Ninth Circuit treated the late petition as timely by tolling the deadline, the Supreme Court reversed and sent the case back for further proceedings.

Real world impact

The decision enforces a strict 14-day deadline for asking permission to appeal class-certification decisions and prevents appeals courts from forgiving late petitions when the opposing party objects. The Court did not decide other timing questions about motions for reconsideration and left those issues for the lower court to address on remand.