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02-1205 JONES v. R. R. DONNELLEY & SONS CO. Ruling below: CA 7, 305 F.3d 717. QUESTION PRESENTED FOR REVIEW Does the four-year "catch-all" limitations period of 28 U.S.C. §1658 apply to new causes of action created by public law 102-166, 105 Stat. 1071, the Civil Rights Act of 1991, which were codified at 42 U.S.C. §1981(a) and (b)? CERT. GRANTED: 5/19/03
The U.S. Supreme Court case Edith Jones et al., on behalf of herself and a class of others similarly situated v. R.R. Donnelley & Sons Company, 2003 revolved around the issue of racial discrimination in employment practices under the Civil Rights Act of 1964 and whether such claims were subject to federal or state statutes of limitations periods for filing lawsuits. The plaintiffs, African-American former employees at R.R Donnelley & Sons Company's Chicago manufacturing division alleged that they had been subjected to a racially hostile work environment and discriminatory employment practices including wrongful termination based on race during their tenure from the late 1960s through early 1980s but did not file suit until after May 1995 when Illinois' two-year statute limitation period had expired. The defendant argued that these claims should be dismissed as untimely because they fell outside this limit while plaintiffs contended that their claim was timely under federal law which has no explicit time limit for bringing such suits.The Supreme Court ruled in favor of the defendants stating that although there is no specific statute-of-limitations period provided by Congress within Title VII (the section addressing workplace discrimination), it does not mean an indefinite timeframe exists for filing complaints; instead, courts must borrow from appropriate state laws regarding similar issues.
In the dissenting opinion for Edith Jones et al., v. R.R. Donnelley & Sons Company, Justice Clarence Thomas disagreed with the majority's interpretation of Section 1658(a) of Title 28, which provides a four-year statute of limitations for any civil action arising under an Act of Congress enacted after December 1, 1990. The majority held that this provision applied to all causes of action recognized by federal courts after that date regardless if they were based on pre-existing laws or not. However, Justice Thomas argued that this interpretation was incorrect and expanded the scope beyond what Congress intended when it passed Section 1658(a). He believed that only those claims explicitly created by statutes enacted post-December 1,1990 should be subject to its four-year limitation period while others should follow their respective specific or general time limits provided in other sections.