Chase Securities Corp. v. Donaldson

In Chase Securities Corp. v. Donaldson (1945) 325 U.S. 304, 315 65 S. Ct. 1137, 1143-1143, 89 L. Ed. 1628, the Supreme Court rejected a constitutional challenge to an amendment to the Minnesota Blue Sky laws that operated to abolish the defendant's statute of limitations defense in pending litigation. Justice Jackson, writing for a unanimous court, acknowledged that when the litigation against it was commenced, the defendant had a legitimate expectation that it could defend the claim by invoking the relevant statute of limitations, and that this expectation had been disappointed by the change in the law. This disappointment, however, did not rise to the level of a constitutional violation because "whatever grievance appellant may have at the change of policy to its disadvantage, it had acquired no immunity from this suit that has become a federal constitutional right." (Chase Securities Corp. v. Donaldson, supra, 325 U.S. at p. 316 65 S. Ct. at p. 1142.)