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652 KB
Extraction Summary
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Document Information
Type:
Legal document
File Size:
652 KB
Summary
This legal document page discusses the second step of the Landgraf analysis, a legal test to determine if a statute can be applied retroactively. It cites Supreme Court precedent from the Landgraf case to explain that a statute is impermissibly retroactive if it impairs rights, increases liability, or imposes new duties for past conduct, but clarifies that changes to procedural rules are generally not considered retroactive. The document also references the case of Vernon v. Cassadaga Valley Cent. School Dist. as an example of the court considering a new statute of limitations.
People (1)
| Name | Role | Context |
|---|---|---|
| Judge Nathan | Judge |
Mentioned as having correctly resolved the Landgraf step one analysis regarding the statute of limitations.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Congress | government agency |
Mentioned for having expressly extended the statute of limitations to pre-enactment conduct.
|
| Supreme Court | judicial body |
Cited as the source for the explanation of the Landgraf test for retroactivity.
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| Cassadaga Valley Cent. School Dist. | school district |
Named as a party in the court case Vernon v. Cassadaga Valley Cent. School Dist.
|
Timeline (3 events)
1995
The case of Vernon v. Cassadaga Valley Cent. School Dist., 49 F.3d 886 (2d Cir. 1995) was decided, where the Court considered a new statute of limitations.
2d Cir.
The Supreme Court case Landgraf, cited as 511 U.S., which established a two-step analysis for determining the retroactive effects of a statute.
Key Quotes (6)
"[e]ven absent specific legislative authorization,” applying a statute to pre-enactment conduct “is unquestionably proper in many situations."Source
— Supreme Court
(Quoted from the Landgraf case (511 U.S. at 273) to explain the second step of the retroactivity analysis.)
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Quote #1
"A statute does not operate ‘retrospectively’ merely because it is applied in a case arising from conduct antedating the statute’s enactment, or upsets expectations based in prior law."Source
— Supreme Court
(Quoted from the Landgraf case (Id. at 269) to define what does not constitute retrospective operation of a statute.)
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Quote #2
"would impair rights a party possessed when he acted, increase a party’s liability for past conduct, or impose new duties with respect to transactions already completed."Source
— Supreme Court
(Quoted from the Landgraf case (Id. at 280) to define the conditions under which a statute would have an impermissible retroactive effect.)
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Quote #3
"the fact that a new procedural rule was instituted after the conduct giving rise to the suit does not make application of the rule at trial retroactive,"Source
— Supreme Court
(Quoted from the Landgraf case (Id. at 275) to distinguish procedural rules from substantive ones in retroactivity analysis.)
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Quote #4
"diminished reliance interests in matters of procedure"Source
— Supreme Court
(Quoted from the Landgraf case (Id. at 275) as a reason why procedural rules are less likely to be considered impermissibly retroactive.)
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Quote #5
"[b]ecause rules of procedure regulate secondary rather than primary conduct."Source
— Supreme Court
(Quoted from the Landgraf case (Id. at 275) as another reason why procedural rules are treated differently in retroactivity analysis.)
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Quote #6
Full Extracted Text
Complete text extracted from the document (1,648 characters)
Case 22-1426, Document 79, 06/29/2023, 3536060, Page50 of 93
37
The reach of the 2003 amendment to Section 3283 is clear. Because Congress has expressly extended the statute of limitations to pre-enactment conduct, Judge Nathan correctly resolved this analysis at Landgraf step one. In the alternative, however, the statute is— at worst—ambiguous. If the Court takes that view, it should proceed to Landgraf step two, which examines the retroactive effects of the statute.
ii. Landgraf Step Two
As the Supreme Court explained in Landgraf, “[e]ven absent specific legislative authorization,” applying a statute to pre-enactment conduct “is unquestionably proper in many situations.” 511 U.S. at 273. “A statute does not operate ‘retrospectively’ merely because it is applied in a case arising from conduct antedating the statute’s enactment, or upsets expectations based in prior law.” Id. at 269. Instead, the question is whether the statute “would impair rights a party possessed when he acted, increase a party’s liability for past conduct, or impose new duties with respect to transactions already completed.” Id. at 280. Importantly, “the fact that a new procedural rule was instituted after the conduct giving rise to the suit does not make application of the rule at trial retroactive,” because parties have “diminished reliance interests in matters of procedure” and “[b]ecause rules of procedure regulate secondary rather than primary conduct.” Id. at 275.
In Vernon v. Cassadaga Valley Cent. School Dist., 49 F.3d 886 (2d Cir. 1995), this Court considered a new statute of limitations that shortened the time to file
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