Jones v. R.R. Donnelley & Sons

The Civil Rights Act of 1866 created 42 U.S.C. § 1981, which, at the time, guaranteed the rights of all citizens to make and enforce contracts. Section 1981 did not contain a statute of limitations, but in 1987, the Supreme Court ruled that courts should apply the most appropriate statute of limitation under state law to a § 1981 claim. In 1990, Congress enacted a catchall statute, 28 U.S.C. § 1658, that established a four-year statute of limitations for all federal laws enacted after December 1, 1990. The Civil Rights Act of 1991 expanded § 1981 to include equal rights to not only formation of contracts, but also all the benefits of a contractual relationship, including rights related to termination of contracts. Jones (plaintiff) was an African American who used to work for R.R. Donnelley & Sons (Donnelley) (defendant) in Illinois. In November 1994, after Donnelley terminated Jones’s employment, Jones filed a class-action suit against Donnelley alleging a racially hostile work environment and wrongful termination. Donnelley moved for summary judgment on the ground that the most appropriate state statute of limitation applying to Jones’s claims was a two-year limitation under Illinois law and that this time period had expired. Jones claimed that the four-year limitation under § 1658 applied. The district court agreed with Jones, finding that Jones’s claims came under the Civil Rights Act of 1991 and thus § 1658 applied because the Civil Rights Act of 1991 was enacted after December 1, 1990. The court of appeals reversed. The United States Supreme Court granted certiorari.