North Star Steel Co. v. Thomas, 515 U.S. 29 (1995)

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certiorari to the united states court of appeals for the third circuit

No. 94-834. Argued April 25, 1995—Decided May 30, 1995*

Respondents filed separate claims under the federal Worker Adjustment and Retraining Notification Act (WARN), which authorizes a civil enforcement action by aggrieved employees or their union against a covered employer who fails to give 60 days notice of a plant closing or mass layoff, but provides no limitations period for such an action. In rejecting petitioner employer's contention that the statute of limitations had run, the District Court in Crown Cork held that the source of the limitations period for WARN suits is state law and that respondent union's suit was timely under any of the arguably applicable Pennsylvania statutes. In North Star, however, another District Court granted summary judgment for petitioner employer, holding respondent employees' suit barred under a limitations period borrowed from the National Labor Relations Act, which the court believed was "more analogous" to WARN than any state law. The Third Circuit consolidated the cases and held that a WARN limitations period should be borrowed from state, not federal, law, reversing in North Star and affirming in Crown Cork.

Held: State law is the proper source of the limitations period for civil actions brought to enforce WARN. Pp. 33-37. (a) Where a federal statute fails to provide any limitations period for a new cause of action, this Court's longstanding and settled practice has been to borrow the limitations period from the most closely analogous state statute. A closely circumscribed and narrow exception to this general rule allows borrowing from elsewhere in federal law when the arguably relevant state limitations periods would frustrate or interfere with the implementation of national policies or be at odds with the purpose or operation of federal substantive law. See, e. g., DelCostello v. Teamsters, 462 U. S. 151, 161, 172. Pp. 33-35. (b) These cases fall squarely inside the general rule, not the exception. The presumption that state law will be the source of a missing

*Together with No. 94-835, Crown Cork & Seal Co., Inc. v. United Steelworkers of America, AFL-CIO-CLC, also on certiorari to the same court.


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