Menominee Tribe of Wis. v. United States

Menominee Tribe of Wis. v. United States, 577 U.S. ___ (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.[1] 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.[2]

This article is about the 2016 case decided by the Supreme Court of the United States. For the landmark 1968 Supreme Court decision, see Menominee Tribe v. United States.
Menominee Tribe of Wisconsin v. United States
Argued December 1, 2015
Decided January 25, 2016
Full case nameMenominee Indian Tribe of Wisconsin, Petitioner v. United States
Docket no.14–510
Citations577 U.S. ___ (more)
136 S. Ct. 750; 193 L. Ed. 2d 652
Case history
PriorSummary judgment granted, 841 F. Supp. 2d 99 (D.D.C. 2012); affirmed, 764 F.3d 51 (D.C. Cir. 2014); cert. granted, 135 S. Ct. 2927 (2015).
Holding
Plaintiff was not entitled to equitable tolling because they did not demonstrate "extraordinary circumstances"
Court membership
Chief Justice
John Roberts
Associate Justices
Antonin Scalia · Anthony Kennedy
Clarence Thomas · Ruth Bader Ginsburg
Stephen Breyer · Samuel Alito
Sonia Sotomayor · Elena Kagan
Case opinion
MajorityAlito, joined by unanimous
Laws applied
Contract Disputes Act of 1978, 41 U.S.C. § 7101 et seq.,

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.[3] 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's[4] six-year statute of limitations.[5] 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.[6] 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.[7] 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.[8][upper-alpha 1]

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.[11] Citing Holland v. Florida,[12] Justice Alito reaffirmed that litigants are only entitled to equitable tolling if they diligently pursue their claims and that "extraordinary circumstances" prevented timely filing.[13] Citing Pace v. DiGuglielmo,[14] 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."[15] Justice Alito held that the tribe did not demonstrate extraordinary circumstances in this case, and was therefore not entitled to equitable tolling.[16]

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."[17]

See also

Notes
  1. The Supreme Court noted that the District of Columbia Circuit's opinion created a split with the United States Court of Appeals for the Federal Circuit, which permitted equitable tolling "under similar circumstances" in Arctic Slope Native Assn., Ltd. v. Sebelius,[9] which was another "tribal entity equitable tolling" case.[10]

References
  1. Menominee Tribe of Wis. v. United States, No. 14-510, 577 U.S. ___, slip op. at 1, 3–4, 5–8 (2016).
  2. Menominee Tribe of Wis., slip op. at 1, 5–9.
  3. 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.
  4. 41 U.S.C. § 7101 et seq.
  5. Menominee Tribe of Wis., slip op. at 2–4.
  6. Menominee Tribe of Wis., slip op. at 3–4.
  7. Menominee Tribe of Wis., slip op. at 4 (citing 841 F. Supp. 2d 99 (D.D.C. 2012)).
  8. Menominee Tribe of Wis., slip op. at 4–5 (citing 764 F.3d 51 (D.C. Cir. 2014)).
  9. Arctic Slope Native Assn., Ltd. v. Sebelius, 699 F.3d 1289 (Fed. Cir. 2012).
  10. Menominee Tribe of Wis., slip op. at 5.
  11. Menominee Tribe of Wis., slip op. at 5–9.
  12. Holland v. Florida, 560 U.S. 631, 649 (2010).
  13. Menominee Tribe of Wis., slip op. at 5 (internal citations and quotations omitted).
  14. Pace v. DiGuglielmo, 544 U.S. 408, 418 (2005).
  15. Menominee Tribe of Wis., slip op. at 5–6 (internal citations and quotations omitted).
  16. Menominee Tribe of Wis., slip op. at 7–9.
  17. Ronald Mann, Opinion analysis: Justices rebuff tribe’s claim for equitable tolling in government-contract dispute, SCOTUSblog (Jan. 25, 2016)
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