American Pipe in Arnold v. Dirrim

In American Pipe in Arnold v. Dirrim, 398 N.E.2d 426 (Ind. Ct. App. 1979), the court held that the filing of a complaint, which sought to initiate a class action suit, constituted a filing by all persons who were later determined to be members of the certified class; and thus certain class members were not barred by the applicable statute of limitations. Arnold, 398 N.E.2d at 440. The court found American Pipe "particularly persuasive" and stated that the "reasoning of American Pipe applied with equal force." Id.