In the case of Artis v. District of Columbia, 2017, Stephanie Artis sued the District of Columbia in federal court for alleged violations under Title VII and three D.C. laws after she was terminated from her job with the city's Department of Health. The district court dismissed her Title VII claims and declined to exercise supplemental jurisdiction over her local law claims, which were then refiled in D.C Superior Court more than a year later but within the tolling period provided by a federal statute (28 U.S.C §1367(d)). However, this suit was dismissed as untimely because it exceeded D.C.'s three-year statute of limitations for such cases. Artis appealed to the Supreme Court arguing that §1367(d)'s instruction to "toll" a state limitations period means to hold it in abeyance while litigating federally; thus pausing or suspending it during that time rather than providing only an additional 30-day grace period post-dismissal as interpreted by lower courts. The Supreme Court ruled 5-4 in favor of Artis stating that 'tolled' indeed means suspended or paused thereby allowing plaintiffs like Artis extra time equal to what they had left on their state claim when they first filed federally plus thirty days after dismissal.

In the dissenting opinion for ARTIS v. DISTRICT OF COLUMBIA, Justice Neil Gorsuch disagreed with the majority's interpretation of 28 U.S.C §1367(d), arguing that it does not grant a plaintiff an additional period equal to the state statute of limitations after dismissal of federal claims. Instead, he believed it merely guarantees plaintiffs a minimum 30-day window post-dismissal to refile their claims in state court, regardless of whether or not this exceeds the original limitation period. He argued that this reading is more consistent with traditional rules governing statutes of limitations and tolling provisions. Furthermore, he criticized the majority’s decision as being overly generous towards plaintiffs and potentially disruptive to states’ ability to manage their own courts and laws.