In Holmberg et al. v. Armbrecht et al., the U.S Supreme Court ruled that equitable tolling, a legal principle that allows courts to extend statutory deadlines in certain circumstances, applies to federal claims of fraudulent concealment even if state law does not recognize it. The case involved a dispute over land ownership between two parties who had inherited their interests from common ancestors. One party (Holmberg) claimed they were unaware of their rights due to the other party's (Armbrecht) fraudulent concealment and thus should be exempted from New York’s 10-year statute of limitations for bringing such a claim. The court held that equity often acts in disregard of technical requirements when someone has been wrongfully deceived or kept in ignorance and therefore allowed Holmberg's claim despite its lateness under state law.

In the dissenting opinion for Holmberg et al. v. Armbrecht et al., Justice Robert H. Jackson argued that the majority's decision to apply equitable tolling in this case was a departure from established legal principles and precedent, which could lead to uncertainty and unpredictability in future cases. He contended that statutes of limitations are designed not only to protect defendants from stale claims but also to provide certainty and finality in legal matters, thereby promoting stability and fairness in the law. By allowing an exception based on fraudulent concealment, he believed that the Court was effectively rewriting legislation enacted by Congress - a power it does not possess under the Constitution - while also potentially opening up floodgates for other exceptions down the line.