Menominee Tribe of Wisconsin v. United States, 577 U.S. 250 (2016), was a case in which the Supreme Court of the United States clarified when litigants are entitled to equitable tolling of a statute of limitations., slip op. at 1, 3–4, 5–8 (2016). In a unanimous opinion written by Justice Samuel Alito, the Court held that the plaintiff in this case was not entitled to equitable tolling of the statute of limitations because they did not demonstrate that "extraordinary circumstances" prevented the timely filing of the lawsuit.Menominee Tribe of Wis., slip op. at 1, 5–9.
Background This case began as a contract dispute between the Menominee Tribe of Wisconsin and the federal government where the tribe alleged that the federal government failed to adequately fund aid programs under the Indian Self-Determination and Education Assistance Act of 1975.Menominee Tribe of Wis., slip op. at 1–2 (citing Indian Self-Determination and Education Assistance Act, Pub. L. 93–638, 88 Stat. 2203, 25 U.S.C. § 450 et seq. The federal government argued that the Tribe should not have been allowed to bring their claims because they were not filed within the Contract Disputes Act's41 U.S.C. § 7101 et seq. six-year statute of limitations.Menominee Tribe of Wis., slip op. at 2–4. The Tribe, on the other hand, argued that the statute of limitations should be equitably tolled because a similar class action suit was pending for 707 days before the Tribe filed suit.Menominee Tribe of Wis., slip op. at 3–4. The United States District Court for the District of Columbia ruled that the Tribe was not entitled to equitable tolling because they did not demonstrate "extraordinary circumstances", which are a prerequisite for a claim for equitable tolling.Menominee Tribe of Wis., slip op. at 4 (citing 841 F. Supp. 2d 99 (D.D.C. 2012)). On appeal, the United States Court of Appeals for the District of Columbia Circuit affirmed the district court's ruling, and the Supreme Court of the United States ultimately granted certiorari to resolve a circuit split about the circumstances under which litigants are entitled to equitable tolling.Menominee Tribe of Wis., slip op. at 4–5 (citing 764 F.3d 51 (D.C. Cir. 2014)).
Opinion of the Court In a unanimous opinion written by Justice Samuel Alito, the Court held that the tribe was not entitled to equitable tolling of the statute of limitations.Menominee Tribe of Wis., slip op. at 5–9. Citing Holland v. Florida,Holland v. Florida, . Justice Alito reaffirmed that litigants are only entitled to equitable tolling if they diligently pursue their claims and that "extraordinary circumstances" prevented timely filing.Menominee Tribe of Wis., slip op. at 5 (internal citations and quotations omitted). Citing Pace v. DiGuglielmo,Pace v. DiGuglielmo, . Justice Alito also reaffirmed that these two factors are "elements" that should be considered together, and that they are "not merely factors of indeterminate or commensurable weight."Menominee Tribe of Wis., slip op. at 5–6 (internal citations and quotations omitted). Justice Alito held that the tribe did not demonstrate extraordinary circumstances in this case, and was therefore not entitled to equitable tolling.Menominee Tribe of Wis., slip op. at 7–9.
Commentary and analysis In his review of the case for SCOTUSblog, Ronald Mann observed that "the case is likely to cast a shadow over equitable tolling cases for years to come" and suggested that "[f]uture Indian tribes with similar problems may well wish that the tribe in this case had accepted its defeat at the court of appeals without pushing for such a stern limitation on the doctrine from the Supreme Court itself."Ronald Mann, Opinion analysis: Justices rebuff tribe’s claim for equitable tolling in government-contract dispute, (Jan. 25, 2016)
See also Menominee Tribe v. United States List of United States Supreme Court cases Lists of United States Supreme Court cases by volume List of United States Supreme Court cases by the Roberts Court
Notes
References
External links