11th Circ. Strikes Back At Untimely ‘Piggyback' Class Actions

Suppose that you have been successful in defeating a proposed class action. The glow of success begins to fade, however, when your client is hit with another putative class action by a member of the first class. Worse yet, that second class claim looks like one that should be barred by the statute of limitations, but the plaintiff argues that the new class claim was tolled while the initial class action was pending. Finally, you learn that the federal courts of appeals have been busy narrowing the general principle that a pending class action only can toll the statute of limitations as to later filed individual claims by allowing, at least in some circumstances, a later filed class claim to benefit from tolling. What happened to my statute of limitations defense and apparent victory? Is there any end to proposed class claims in this life short of a class settlement or a complete victory on the merits?