Nutraceutical Corp. v. Lambert (17-1094)

argument 17-1094

Nutraceutical Corp. v. Lambert

Supreme Court of the United States 1h 0m 7 speakers 8 chapters transcribed 4 days ago official recording ↗

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What is the central dispute in Nutraceutical Corp. v. Lambert and why does it matter?

John G. Roberts 0:00

We'll hear argument first this morning, case 17-1094, Nutraceutical Corporation v. Lampert.

Paul D. Clement 0:06

Mr. Houston. Mr. Chief Justice, and may it please the Court. In the proceedings below, respondent filed his Rule 23F petition months late and Nutraceutical timely objected. Although this Court has held that mandatory claim processing rules are unalterable When properly invoked, the Ninth Circuit in this case created broad and unprecedented equitable exceptions to excuse Lambert's late filing. Critically, in this case, this Court has twice considered language in a Federal rule that is virtually identical to the Federal rules at issue in this case. And in both those cases, in the Carlisle and the Robinson cases, This Court rejected equitable exceptions, even when faced with facts far more empathetic than those presented here.

Ruth Bader Ginsburg 1:04

Counselor, I thought that both sides agreed that if the motion for reconsideration is filed within 14 days, within that period, then there is tolling until the motion is decided. Is that so?

Paul D. Clement 1:25

That is correct, Justice Ginsburg.

Ruth Bader Ginsburg 1:28

And isn't that a form of equitable tolling?

Paul D. Clement 1:31

It is not a form of equitable tolling, Your Honor. Instead, as held by this Court in U.S. v. Dieter, it's based on a traditional and virtually unquestioned practice that is premised upon three main policy points to prevent premature appeals, to develop and strengthen the record, and to respect the authority of the district court. It's important to realize that this doctrine could not open the door to equitable exceptions for claim processing rules because in the Ibarra, Dieter, and Healy cases, those dealt with a statute, 3731, establishing the deadline in a criminal case, and thus it was a jurisdictional case. So the application of that rule in the context of a criminal case with jurisdictional rules, in fact, told those jurisdictional deadlines.

Paul D. Clement 2:27

And so, therefore, pursuant to the Court's holdings in Hamer and elsewhere, that is not an equitable exception.

Elena Kagan 2:36

Mr. Houston, given the reasons that you just stated for that rule, why is the rule limited to a motion for reconsideration that's filed during the 14-day window? In other words, suppose the motion for reconsideration was filed in a timely manner for such a motion, but after the 14-day period, why wouldn't the same reasons apply?

Paul D. Clement 2:59

Because, Your Honor, if that reasoning applied, in this instance, for instance, there was actually no deadline for filing of a motion for reconsideration in the Central District of California. But let's assume for purposes of your question we had a 30-day deadline. If that 30-day deadline were imposed in this case- and one could file on the 30th day and begin tolling, that would render the 14-day deliberately small window that the advisory committee drafters created in order to minimize the disruption and delay in the context of class action cases a nullity. Because in any instance where you would have a longer deadline for a motion for reconsideration, you could wait out that period and and avoid the window that was intentionally created by the drafters.

Paul D. Clement 3:55

And I would like to direct the Court's attention specifically to the Advisory Committee notes to the 1998 amendment to Rule 23F, where they specifically stated the importance of the short window to deliberately keep the time as short as possible.

Elena Kagan 4:11

It just seems as though the exception that you admit, which is the exception for filing a motion for reconsideration within the 14-day period also effectively renders that 14-day period annulity, right? Because it stops it in its tracks, and then once the motion for reconsideration has been dealt with, as I understand the agreement between the parties, the clock goes all the way back to the beginning. So given that what you — the exception you admit renders the 14-day period annulity, again, I just wonder why the exact same reasons, practices — traditions don't suggest that, for example, as the example you gave, if the motion for reconsideration is timely filed within 30 days, that as long as you do that, it should have the same effect?