China Agritech v. Resh
In brief
China Agritech says a failed class case does not extend the deadline for an unnamed member to file another class action.
- Where it stands
- Decided
Decided 9-0 · June 11, 2018 · Opinion by Justice Ginsburg
- What it’s about
- The case asked whether people who were unnamed members of an earlier proposed class action can file a new class action after the statute of limitations has run.
- Who it affects
- People covered by a proposed class action can still use the American Pipe rule to bring their own individual claims later. But they cannot use that rule to start a successive class action after the deadline.
Summary: written with AI from the case record.
What it's about
The Supreme Court held that American Pipe tolling lets those class members bring individual claims later, but it does not let them start a successive class action outside the limitations period.
The decision limits repeated attempts to bring class actions after a court has refused to certify an earlier proposed class.
Question presented
Whether the American Pipe rule tolls statutes of limitations to permit a previously absent class member to bring a subsequent class action outside the applicable limitations period.
What the Court decided
Holding
Upon denial of class certification, a putative class member may not, in lieu of promptly joining an existing suit or promptly filing an individual action, commence a class action anew beyond the time allowed by the applicable statute of limitations. 857 F. 3d 994, reversed and remanded.
- Result
- Reversed
The vote
- Joined the judgment
- Concurred in a separate opinion
- Wrote an opinion
- Majority · 8joined the Court's opinion
- Concurring · 1agreed with the result, wrote separately
- Sotomayorwrote separately
What's next
The case returns to the lower court, which must apply the Supreme Court's rule. The Court has finished its work in this docket.
Documents
Docket activity
New analysis added
AI analysis generated: Case Briefing
AI analysis generated: Decision Record
Opinion added: opinion
Brief added: Questions Presented
More questions
- What did the Supreme Court decide in China Agritech v. Resh?
- The Court said unnamed members of a proposed class cannot file a new class action after the filing deadline expires. They must act promptly in the existing case or file individual claims.
- How does American Pipe tolling work after this ruling?
- American Pipe tolling can preserve individual claims while a proposed class action is pending. It does not preserve the right to start a later class action after the deadline.
- Who wrote the China Agritech opinion?
- Justice Ginsburg wrote the Court's opinion, and eight justices signed it. Justice Sotomayor agreed with the result in a separate opinion.
- What happens next in China Agritech?
- The Supreme Court sent the case back to the lower court. That court must handle further proceedings under the Supreme Court's deadline rule.
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.