CTS Corp. v. Waldburger (13-339)
argument 13-339CTS Corp. v. Waldburger
Supreme Court of the United States
1h 0m
5 speakers
8 chapters
transcribed 5 days ago
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What is the purpose of Section 96‑58 in the CTS Corp. v. Waldburger case?
We'll hear argument next in case thirteen thirty three thirty nine, CTS Corporation versus Waldberger. Mr Murray?
Mr Chief Justice, and may it please the court. CTS should prevail here based on the text of Section ninety six fifty eight as well as its structure, historical context, and other relevant considerations, all of which make clear that it is a federalism compromise having no effect on statutes of reposed. Section ninety six fifty eight should be construed narrowly to do the one thing that Congress intended it to do, which is to postpone in some situations a single state law statute of limitations commencement date.
How many how many states Have a This is this is a general statute of oppose. It had nothing to do in particular with circle. Is that right?
That's right.
And how many states have such That's it.
Well it it gets a little confusing. The study group report um indicated there were four of those states. I believe respondents have pointed to four or five. There are also that have to do with personal injury. There are also myriad others that have to do with property damage, so it gets a little confusing to give a strict answer to that. Um but there were four statutes of repos squarely in the study group before uh before Congress when they enacted this. Um so Congress knew about these statutes of repos uh when they enacted this.
But if you were to prevent Well no The parties concern might well go to their state legislatures and say an act a statute of repos. That will get us off the hook. Even before The injured person is aware of the injury and of the cause of it. The result of that would be to totally defeat what I was Meant to do. And same. The trigger is when you know the cause of the injury.
Um there has not been a rash of moves to state legislatures since this law has been enacted, so we haven't seen that develop. But um if I could respectfully disagree with the premise, I think Congress's purpose here was slightly narrower um than saving all long latent injury claims. I think what Congress was worried about was expedition and making sure that it didn't force people to come to court. before under a statute of limitations uh before they would be expected to. And that's set out if the statute itself accomplishes only one thing, section A one, and I'm reading from page one of our opening brief to the court, it does one thing only, which is if The applicable limitations period for one of these actions, as specified in a state law statute of limitations or under common law, provides a commencement date that is earlier than the federal commencement date, then it substitutes the more favorable commencement date.
commencement date in turn if we turn to page two and this is reading now from B three Commencement date means the date specified in a statute of limitations as the beginning of the applicable limitations period. Which again, um B two applicable limitations period, is defined as the period specified in a statute of limitations during which one of these civil actions may be brought. So doing the algebra on the definitions, what Congress surgically wanted to do here was to change one thing and one thing only, if you had a less favorable state commencement date, which is the beginning of which an action may be brought, which is accrual. If you have one of these less favorable state commencement dates for statute of limitations, Congress wanted to move that, keeping in place
why would it have wanted to do that and not also get rid of the um
uh
statute of repos? I mean presumably the idea is You should have some chance to sue. after you've discovered the injury and the cause of the injury and if here the statute of repose is preventing that Why would Congress have wanted to modify a statute of limitations but not Get rid of the statute of repose.
I think Congress was trying to be very careful with what it was doing in this area because it knew it was operating in pretty much the heartland of state law and state prerogatives here. And so while it was willing to go as far as the one study group recommendation and change statutes of limitations, a procedural mechanism, it wasn't willing to go right into the heart of the elements of the cause of action and start changing those because it perceived potentially serious federalism problems with doing that.
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Chapters
8 chapters
1
What is the purpose of Section 96‑58 in the CTS Corp. v. Waldburger case?
0:02–7:43
2
How does the Court interpret the term “commencement date” for statutes of limitations?
7:43–16:01
3
Why do the parties argue about whether a statute of repose applies in this case?
16:01–24:40
4
What is the significance of the “four states” that had statutes of repose when the law was enacted?
24:40–31:52
5
How do the justices distinguish between statutes of limitations and statutes of repose?
31:52–39:27
6
What role does the discovery rule play in Congress’s compromise under Section 96‑58?
39:27–46:20
7
How might a hybrid or bifurcated statute of limitations affect the plaintiff’s claim?
46:20–53:02
8
What policy considerations drive Congress’s decision to preserve latent‑harm claims while limiting repose periods?
53:02–1:00:50