Opinion · Supreme Court of the United States

Holmberg v. Armbrecht

327 U.S. 392

Type
Opinion
Court
Supreme Court of the United States
Jurisdiction
Federal
Date
1946-02-25
Topic
general

How later courts describe this case

  • holding that equitable doctrine of fraudulent concealment is read into every federal statute of limitations
  • holding that an issue not raised before the IJ or ruled on by the IJ was not properly before the BIA
  • holding that Erie does not require federal courts to apply state tolling doctrines to federal causes of action
  • holding that while state law determines limitations period when no federal limitations period is provided, federal law determines date on which limitations period begins to run
  • concluding that the equitable doctrine of fraudulent concealment “is read into every federal statute of limitation”
  • holding that limitations periods are subject to equitable tolling where tolling is not inconsistent with the statute
  • holding that equitable tolling due to defendant’s fraudulent concealment “is read into every federal statute of limitation”
  • holding that the general equitable tolling doctrine “is read into every statute of limitations”

Citator

UpLaw has not yet analyzed Holmberg v. Armbrecht. The absence of a flag is not a finding that it is good law.

Cited by
1485 opinions

Headnotes

  1. Civil Procedure — Statute of Limitations The decision of a suit in a federal court to enforce a federally created equitable right is not controlled by the statute of limitations of the State of the forum; Guaranty Trust Co. v. York, which applies state limitations to state-created rights in diversity suits, is inapplicable to the enforcement of federal equitable rights. 327 U.S. 392, 394
  2. Remedies — Statutes of Limitations — Laches Statutes of limitations are not controlling measures of equitable relief; equity draws upon them only for the light they shed in determining whether the plaintiff has inexcusably slept on his rights so as to make a decree against the defendant unfair. A court of equity may dismiss a suit for want of diligence even though the action is not barred by the applicable statute of limitations. 327 U.S. 392, 396
  3. Remedies — Fraud — Accrual of the Statute of Limitations Under the settled chancery rule, where a plaintiff has been injured by fraud and remains in ignorance of it without fault or want of diligence on his part, the bar of the statute of limitations does not begin to run until the fraud is discovered, even absent special efforts by the wrongdoer to conceal it. 327 U.S. 392, 397
  4. Civil Procedure — Statute of Limitations The equitable doctrine that a limitations period does not begin to run until the plaintiff discovers, or in reasonable diligence should have discovered, the fraud is read into every federal statute of limitations; where Congress has enacted no explicit period for a federally created right, the court will not confine that right within the bare terms of a state statute of limitation unrelieved by that federal equitable doctrine. 327 U.S. 392, 397
  5. Civil Procedure — Federal Courts — Federal Equitable Rights Federal courts, sitting as national courts throughout the country, must apply their own principles in enforcing an equitable right created by Congress; where Congress leaves to the federal courts the formulation of remedial details, they are not expected to break with historic principles of equity in enforcing federally created equitable rights. 327 U.S. 392, 395