Artis v. District of Columbia

In Artis v. District of Columbia, Stephanie Artis sued her former employer, the District of Columbia, asserting claims under federal law (FLSA, ADA, Title VII) and local District of Columbia law (D.C. Wage Payment Act). The federal district court dismissed her federal claims and declined to exercise supplemental jurisdiction over her local-law claims. Artis subsequently refiled her local-law claims in the D.C. Superior Court. The central issue was whether 28 U.S.C. § 1367(d) tolled the statute of limitations for her state-law claims. The Supreme Court, in a 5-4 decision, held that § 1367(d)’s tolling provision applies only where federal jurisdiction is based solely on supplemental jurisdiction, not where, as here, the federal court had original federal-question jurisdiction over related claims. Consequently, her state-law claims were deemed time-barred.

The Supreme Court affirmed the lower court's judgment, holding that 28 U.S.C. § 1367(d) does not toll the statute of limitations in such circumstances. Artis's local-law claims were therefore dismissed as untimely.

The core dispute was whether the tolling provision of 28 U.S.C. § 1367(d) applies to suspend the statute of limitations for related state-law claims dismissed after a federal court declines supplemental jurisdiction, even when the court possessed original jurisdiction over accompanying federal claims, or whether it applies only when supplemental jurisdiction is the sole basis for federal jurisdiction.

The decision significantly restricted plaintiffs' ability to refile state-law claims in state court after a federal dismissal, clarifying that the tolling provision of § 1367(d) applies only in cases purely based on supplemental jurisdiction. It underscored a strict textualist approach to statutory interpretation of jurisdictional rules and heightened procedural risks for litigants pursuing parallel federal and state claims in federal court.