Class action appeal deadlines
Nutraceutical v. Lambert
In brief
The Supreme Court ruled that the Rule 23(f) deadline cannot be extended for fairness reasons and overturned the Ninth Circuit's judgment.
- Where it stands
- Decided
Decided 9-0 · February 26, 2019 · Opinion by Justice Sotomayor
- What it’s about
- In Troy Lambert’s class-action suit against Nutraceutical, the Ninth Circuit allowed an exception to Rule 23(f)’s 14-day deadline for seeking permission to appeal a class-certification order.
- Who it affects
- Parties seeking permission to appeal class-certification orders under Rule 23(f) cannot use a fairness-based exception to extend the deadline.
Summary: written with AI from the case record.
What it's about
The Supreme Court ruled that the deadline cannot be extended on fairness grounds (equitable tolling), overturned the Ninth Circuit, and sent the case back to the lower court (remanded).
Rule 23(f) sets a 14-day period to ask an appeals court for permission to review an order granting or denying class-action certification.
Question presented
Did the Ninth Circuit err by holding that equitable exceptions apply to mandatory claim-processing rules and excusing a party's failure to timely file a petition for permission to appeal, or a motion for reconsideration, within the Rule 23(f) deadline?
What the Court decided
Holding
Rule 23(f) is not subject to equitable tolling. 870 F. 3d 1170, reversed and remanded.
- Result
- Reversed
The vote
What's next
The case returns to the Ninth Circuit for further proceedings consistent with the Supreme Court's ruling.
Documents
Docket activity
New analysis added
AI analysis generated: Case Briefing
AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
Case data updated: question_presented, extraction_metadata
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Opinion added: Lambert
Opinion added: opinion
Brief added: Petition
Brief added: Questions Presented
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.