RESPONDENT:United States, et al.
LOCATION: Menominee Indian Tribe Tribal Offices
DOCKET NO.: 14-510
DECIDED BY: Roberts Court (2010-2016)
LOWER COURT: United States Court of Appeals for the District of Columbia Circuit
CITATION: 577 US (2016)
GRANTED: Jun 30, 2015
ARGUED: Dec 01, 2015
DECIDED: Jan 25, 2016
Geoffrey D. Strommer – for the petitioner
Ilana Eisenstein – for the respondents
Facts of the case
Between 1995 and 2004, the Menominee Indian Tribe of Wisconsin (Menominee Tribe) provided healthcare services to members of the tribe pursuant to a self-determination contract with the Secretary of Health and Human Services (HHS). The self-determination contract states that the federal government will pay the participating tribe the amount that the government would have paid the Department of the Interior and HHS if those agencies were administering the program. The tribe and the government negotiate those costs in annual funding agreements.
In 2005, the Menominee Tribe filed administrative claims with the HHS’s Indian Health Service to recover contract support costs for the years 1995 through 2004. The claims were denied for the years 1996 through 1998 as untimely because the six-year statute of limitations had run. The Menominee Tribe challenged that decision in federal district court and argued that the statute of limitations should not have been running. The district court rejected the Menominee Tribe’s argument. The U.S. Court of Appeals for the District of Columbia Circuit remanded the case for further consideration, and the district court again held that the statute of limitations had run. The appellate court affirmed and held that there were no extraordinary circumstances that should have prevented the statute of limitations from running.
Did the U.S. Court of Appeals for the District of Columbia Circuit properly hold that there were no extraordinary circumstances present in this case that would have prevented the statute of limitations from running?
Media for Menominee Indian Tribe of Wisconsin v. United States
Audio Transcription for Opinion Announcement – January 25, 2016 in Menominee Indian Tribe of Wisconsin v. United States
John G. Roberts, Jr.:
Justice Alito has the opinion of the Court in case 14 510, Menominee Indian Tribe of Wisconsin versus United States and he has asked that I read the announcement of the opinion.
This case comes to us on a Writ of Certiorari to the United States Court of Appeals for the District of Columbia Circuit.
It concerns the circumstances in which equitable tolling should apply.
Equitable tolling sometimes allows a party to extend a deadline or Statute of Limitations.
Courts allow equitable tolling only under extraordinary circumstances and where the party, seeking tolling, has been diligently pursuing its rights.
The question in this case is whether a mistake of law to proceed from futility of filing a claim or the cost and risk of litigation can justify equitable tolling.
Here petitioner is an Indian tribe that contracts with the Federal Government to provide health services to the tribe members.
Federal law requires the government to reimburse tribal contractors for certain contract and cost.
The tribe believed that the government did not reimburse some contracting costs in full but the tribe did not file claims for those costs until after a six-year statutory deadline had elapsed.
It filed so late because it believed, mistakenly as it turns out, that its filing deadline was extended by an abortive class action lawsuit on the same issue.
The District Court refused to apply equitable tolling to the filing deadline and the District of Columbia Circuit agreed holding that equitable tolling is appropriate only where an external obstacle stands in the way of timely filing.
We affirm the judgment of the DC Circuit.
We hold that a litigant seeking equitable tolling must show that the circumstances causing delay were both extraordinary and beyond the litigant’s control.
Now in this case the tribe’s mistake of law about the class-action, the perceived futility of filing a claim and the costs and risks of litigation do not justify tolling.
And while we do not question the general trust relationship between the United States and the Indian tribes, that relationship does not override a clear statutory deadline.
Our decision is unanimous.