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Keywords

defendantappealhearingdue processcivil procedureadministrative law

statutestatute of limitationscivil procedure

Related Cases

S.J. v. Issaquah School Dist. No. 411, 470 F.3d 1288, 66 Fed.R.Serv.3d 1397, 214 Ed. Law Rep. 1002, 06 Cal. Daily Op. Serv. 11,286

Facts

S.J. is a juvenile who attended schools in the Issaquah School District until the sixth grade. In 2002, after failing to establish an Independent Education Plan with the district, S.J.'s parents enrolled him in a private special education school and subsequently filed for a state due process hearing regarding claims under the IDEA. An administrative law judge issued a final order on August 12, 2004, which S.J. was advised to appeal within thirty days. S.J. filed his complaint in federal court on September 13, 2004, but attempted to serve the defendants only on September 14, 2004.

S.J. is a juvenile who attended schools in the Issaquah School District through the sixth grade. In 2002, unable to work out an Independent Education Plan with the district, S.J.'s parents enrolled him at a private school for special education students.

Issue

Whether a federal court borrowing a state's time period for filing suit under federal law should also borrow the state's time limits for serving the complaint.

Whether a federal court borrowing a state's time period for filing suit brought under federal law should not also borrow the state's time limits for serving the complaint.

Rule

Federal procedural rules govern the commencement of actions and the time limit for service of process, specifically Rule 3 and Rule 4(m) of the Federal Rules of Civil Procedure.

We have previously held that Rule 3 of the Federal Rules of Civil Procedure controls when an action which arises under federal law is 'commenced' for purposes of tolling the statute of limitations borrowed from state law.

Analysis

The court determined that S.J.'s action was timely commenced under Rule 3 when he filed his complaint within the thirty-day period after the administrative order. The court held that federal rules should apply to the service of process, meaning that the state’s service requirement did not apply. Thus, S.J.'s failure to serve the complaint within the state’s thirty-day limit did not bar his action under federal law.

As S.J.'s action was commenced under Rule 3 within the thirty-day period of limitations when he filed his complaint in federal district court, the corollary is that Rule 4 controls service of process.

Conclusion

The Court of Appeals reversed the district court's dismissal and remanded the case, concluding that S.J.'s complaint was timely filed and that the federal rules govern the service of process.

Therefore, we hold that a federal court borrowing a state's time period for filing suit brought under federal law should not also borrow the state's time limits for serving the complaint.

Who won?

S.J. prevailed in the case because the Court of Appeals found that his complaint was timely filed under federal rules, which do not require adherence to the state’s service time limits.

S.J. is a juvenile who attended schools in the Issaquah School District through the sixth grade.

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