Episode description

Welcome to Supreme Court Opinions. In this episode, you’ll hear the Court’s opinion in Wilkins v United States. 

In this case, the court considered this issue: Do the Individuals with Disabilities Education Act (I-D-E-A) and the Americans with Disabilities Act (ADA) require a student to exhaust his administrative proceedings against the school district even when such proceedings would be futile?

The case was decided on March 28, 2023. The Supreme Court held that the Quiet Title Act’s 12-year statute of limitations is a claim-processing rule, not a jurisdictional requirement. Justice Sonia Sotomayor authored the 6-3 majority opinion of the Court holding that Wilkins's and Stanton's lawsuit may proceed.

Jurisdictional rules tend to disrupt litigation, whereas procedural rules (including claim-processing rules) seek to facilitate the litigation process. Given the risk of disruption and waste that accompanies the jurisdictional label, courts will view a procedural requirement as jurisdictional only if Congress “clearly states” that it is. As a general rule, most statutes of limitations are non-jurisdictional.

The 12-year statute of limitations described in 28 U.S.C. § 2409a(g) lacks a jurisdictional clear statement, and nothing in its text or context supports departing from the general rule that statutes of limitations are non-jurisdictional. Nor do any of the three cases the government cites definitively interpreted Section 2409a(g) as jurisdictional. Thus, the provision at issue is a claim-processing rule, not a jurisdictional one.

Justice Clarence Thomas dissented, arguing that the Court has long treated conditions on waivers of sovereign immunity, such as the one at issue in this case, as jurisdictional, and he would recognize the Court’s precedents as resolving the question.

The opinion is presented here in its entirety, but with citations omitted. If you appreciate this episode, please subscribe. Thank you.