Massachusetts Supreme Judicial Court

Dunn v. Langevin

July 11, 2023

Summary

The court held that its COVID-19 emergency orders tolling civil statutes of limitations did not extend the statutory deadline for filing a discrimination complaint with the Massachusetts Commission Against Discrimination because the orders governed court operations, not executive agencies. It also held that equitable tolling was unavailable because the plaintiff was not misled, was not excusably ignorant, and failed to use the Commission's available tolling process. The dismissal of the discrimination claims was affirmed, while the case was remanded for proceedings on the remaining claims.