American Pipe and Construction Co., v. Utah
In American Pipe and Construction Co., v. Utah, 414 U.S. 538 (1974), the plaintiff--state ("Utah") filed a complaint in its federal district court, against the defendants--companies, alleging that the defendants engaged in illegal price fixing concerning the sale of concrete and steel. Id. at 541.
As a result of countless actions against the defendants, the U.S. District Court for the District of Utah transferred the case to the U.S. District Court for the Central District of California ("California U.S. District Court"). Id. at 542.
Thereafter, the defendants filed a motion, alleging that Utah did not satisfy class action requirements, and the court agreed. Id. Several days after the court issued its order, additional parties moved to intervene as plaintiffs. Id. at 543-44.
The California U.S. District Court denied the parties' motion, determining that the statute of limitations had expired. Id. at 544. The U.S. Court of Appeals for the Ninth Circuit affirmed and denied in part. Id. at 544-45.
The U.S. Supreme Court granted certiorari to provide the federal courts with a harmonious solution in reviewing these specific type of cases. Id. at 545.
The U.S. Supreme Court examined the differences amongst the courts, as well as the purpose of the statute of limitations, which was advancing justice, ensuring equality, and judicial efficiency. Id. at 554.
In considering these factors, and attempting to capture the spirit of federal class action procedures, the U.S. Supreme Court concluded that, "the commencement of a class action suspend[ed] the applicable statute of limitations as to all asserted members of the class who would have been parties had the suit been permitted to continue as a class action." Id.