Supreme Court Ruling In Statute-Of-Limitations Case Has Wide-Ranging Implications

In Short

The Situation: The Fair Debt Collection Practices Act ("FDCPA") allows plaintiffs to sue over abusive debt-collection practices within one year of "the date on which the violation occurs." 15 U.S.C. § 1692k(d). The U.S. Court of Appeals for the Third Circuit split with the Ninth and Fourth Circuits by holding that the FDCPA's limitations period begins to run at the time of the violation—even if a plaintiff does not discover the violation until later. The Supreme Court granted certiorari to decide whether the so-called "discovery rule"—which delays commencement of statutes of limitations until a violation is or should be discovered—applies to the FDCPA.

The Result: The Supreme Court held that the statute of limitations for FDCPA suits ordinarily begins to run when the FDCPA violation occurs, not when it is discovered. In so doing, the Court endorsed a general interpretive presumption against applying the discovery rule to ambiguous statutes of limitation.