## Facts

- African-American former employees filed a federal class action in 1996 against a printing company alleging race discrimination under 42 U.S.C. § 1981 as amended by the Civil Rights Act of 1991.
- The employees alleged wrongful discharge, refusal to transfer, and a racially hostile work environment.
- Section 1981 contains no express statute of limitations.
- The employer argued the claims were time-barred under Illinois’s two-year limitations period for personal injury actions.
- The employees argued that 28 U.S.C. § 1658(a)’s four-year limitations period applied because their claims were made actionable by the 1991 amendments, enacted after December 1, 1990.
- The district court applied § 1658(a) and held the claims timely.
- The Seventh Circuit reversed, reasoning § 1658(a) applied only to claims created by entirely new statutes enacted after December 1, 1990, not amendments to preexisting statutes.
- The Supreme Court granted review to resolve whether § 1658(a) covers claims made possible by post-1990 amendments to older statutes.

## Issues

1. Whether 28 U.S.C. § 1658(a)’s four-year limitations period applies only to causes of action created by entirely new post-1990 statutes.
2. Whether § 1658(a) also applies to causes of action made possible by post-1990 amendments to preexisting statutes, including § 1981 as amended in 1991.
3. Whether the employees’ § 1981 claims for termination, refusal to transfer, and hostile work environment are governed by § 1658(a) rather than borrowed state limitations law.

## Decision

- The Court reversed the Seventh Circuit and remanded.
- Section 1658(a) applies to any claim “made possible by a post-1990 enactment,” including a post-1990 amendment to an older statute.
- The employees’ asserted § 1981 claims were not actionable under § 1981 before the 1991 amendments and therefore fall within § 1658(a)’s four-year period.

## Legal Principles

- The four-year statute of limitations in 28 U.S.C. § 1658(a) governs a federal claim if the claim was made possible by a statutory enactment after December 1, 1990.
- A post-1990 amendment is an “Act of Congress” for purposes of § 1658(a); the inquiry is functional, focused on whether the enactment created new rights of action and corresponding liabilities.
- Section 1658(a) does not displace borrowed state limitations periods for federal causes of action that existed and were actionable before December 1, 1990.

## Conclusion

The Court held that § 1658(a)’s four-year limitations period applies to federal causes of action made possible by post-1990 enactments, including the 1991 expansion of § 1981, rendering the employees’ claims subject to a uniform four-year period rather than Illinois’s borrowed two-year period.


Jones v. R.R. Donnelley & Sons Co., 541 U.S. 369 (2004)