## Facts

- Stephanie C. Artis, a former District of Columbia health inspector, filed suit in federal court asserting a federal Title VII employment-discrimination claim and three related claims under District of Columbia law.
- The federal court exercised supplemental jurisdiction over the D.C.-law claims under 28 U.S.C. § 1367(a).
- When suit was filed, nearly two years remained on the limitations period for the D.C.-law claims.
- About two and a half years later, the federal court disposed of the federal claim and, under § 1367(c), dismissed the D.C.-law claims without reaching their merits.
- Fifty-nine days after the federal dismissal, Artis refiled the D.C.-law claims in D.C. Superior Court.
- The Superior Court dismissed the refiled action as time-barred, and the D.C. Court of Appeals affirmed, interpreting § 1367(d) to provide only a 30-day grace period to refile.

## Issues

1. Whether the term “tolled” in 28 U.S.C. § 1367(d) suspends the running of the state limitations period while the supplemental claim is pending in federal court (and for 30 days after dismissal), or instead merely provides an additional 30 days to refile after dismissal while the limitations period continues to run during the federal case.

## Decision

- The Supreme Court reversed and remanded.
- The Court held that “tolled” in § 1367(d) means the limitations period is suspended (a “stop-the-clock” rule) while the claim is pending in federal court and for 30 days after dismissal, unless state law provides a longer tolling period.
- Applying that rule, Artis’s D.C.-law claims were timely when refiled 59 days after dismissal because the limitations clock did not run during the federal proceedings and substantial time remained when she first filed in federal court.

## Legal Principles

- Under 28 U.S.C. § 1367(d), the limitations period for supplemental state-law claims is suspended for the entire time the claim is pending in federal court, plus 30 days after the federal court dismisses the claim (unless state law affords a longer tolling period).
- The statute’s structure (“tolled while the claim is pending and for a period of 30 days after it is dismissed”) describes a continuous tolling interval; reading it as only a post-dismissal grace period would largely nullify “while the claim is pending.”
- Section 1367(d) functions to preserve state-law claims when plaintiffs initially pursue them alongside federal claims in federal court and the federal court later declines to retain supplemental jurisdiction.

## Conclusion

The Court interpreted § 1367(d) to stop the limitations clock on supplemental state-law claims while they are pending in federal court and for 30 days after dismissal, protecting plaintiffs from losing state claims solely because they were first litigated under supplemental jurisdiction.


Artis v. District of Columbia, 583 U.S. 71 (2018)