Supreme Court of the United States

Rotella v. Wood

February 23, 2000528 U.S. 549

Summary

Justice Souter delivered the unanimous opinion of the Court, holding that discovery of a pattern of racketeering activity does not postpone the commencement of civil RICO’s four-year limitations period. The Court affirmed the judgment rejecting Rotella’s action as untimely because the injury-and-pattern discovery rule would undermine repose, encourage stale claims, and frustrate Congress’s objective of encouraging prompt private enforcement. The Court did not choose between injury discovery and injury occurrence as the governing accrual rule, and it preserved the availability of equitable tolling in appropriate circumstances. There were no separate opinions.

Holding

  • Whether the injury-and-pattern discovery rule governs accrual of civil RICO claims.. Civil RICO’s limitations period is not governed by an injury-and-pattern discovery rule. Discovery of the racketeering pattern is not required to start the limitations period. The Court left unresolved whether injury occurrence or injury discovery supplies the governing rule.

Docket 98-896

Cited authorities

  • Rule 9(b)
  • Rule 9(b)
  • Rule 11(b)(3)
  • Rule 9(b)
  • 18 U.S.C. §§ 1961-1968
  • CA10
  • CA11
  • 18 U.S.C. §§ 1961-1968

Cited by