1. Plaut v. Spendthrift Farm, Inc. (1995)
2. Facts: A Securities Act violation was committed. After Supreme Court dismissal of the first action for being brought outside of the statute of limitations, Congress passed a new section 27A to the Securities Exchange Act, extending the statute of limitations in these cases, as well as providing for the “reinstatement” of causes of action that had been dismissed on statute of limitations grounds during the time of pendency of the first action in this case, thus re-opening the case.
3. Procedural Posture: In the first action, the Supreme Court dismissed the case for being brought outside of the statute of limitations (which it has prescribed in the Rules). Congress’ enactment of new section 27A reinstated the action.
4. Issue: Whether Congress can reinstate a case that has been previously dismissed on statute of limitations grounds.
5. Holding: No.
6. ∏ Argument: Congress has the power under Article III to modify the appellate jurisdiction of the Supreme Court, which includes statutorily reinstating a class of cases.
7. ∆ Argument: Congress’ power does not include reinstatement of previously decided cases under new laws.
8. Majority Reasoning: Scalia stated that Article III not only gives the federal judiciary the power to rule on cases, but to decide them, subject only to review by superior courts in the Article III hierarchy. “When retroactive legislation requires its own application in a case already finally adjudicated, it does no more and no less than ‘reverse a determination once made, in a particular case.’” Such power is clearly contrary to what the framers contemplated in the separation of powers. It did not matter that the statute was with reference to a general class of cases, and not ostensibly to a particular case, if it gave the Congress the power to reinstate a case, it necessarily interfered with the outcome of a particular case.
