Supreme Court of the United States · 1995 · Constitutional Law
Constitutional LawSeparation of PowersArticle IIIFinality of JudgmentsArticle IIIseparation of powersfinal judgmentretroactive legislation
Facts
Congress enacted § 27A(b) after certain federal securities cases had already been dismissed and had become final. That provision required federal courts to reopen a class of those final judgments and reinstate actions if they would have been timely under the legal regime that existed before the Court's earlier limitations ruling. The statute operated retroactively and applied to cases already finally adjudicated. Only Article III courts were involved in the reopening process; no executive review was contemplated.
Issue
Whether Congress violates Article III and separation-of-powers principles when it enacts retroactive legislation requiring federal courts to reopen final judgments in private civil cases.
Rule
Article III's grant of the judicial power includes the power to render dispositive, conclusive judgments subject to review only within the Article III judicial hierarchy. Congress may change applicable law and may require courts to apply new law to cases still pending on appeal, but Congress may not by retroactive legislation command Article III courts to reopen final judgments and declare that the law governing those already-final cases was something other than what the courts said it was.
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Nina Patel sued Harbor Crest Lending in federal district court in Miami under a federal consumer statute. The court dismissed her suit as untimely, and Nina filed a timely appeal. While the appeal was pending, Congress enacted a statute extending the limitations period and expressly directing federal courts to apply the new period to all cases still pending in the federal appellate process.
How should the court of appeals treat Nina's case?
Explanation. Article III forbids Congress from commanding Article III courts to reopen final judgments, but Congress may change the applicable law and require courts to apply that new law in cases still pending on appeal. A judgment under appellate review is not yet the final word of the Article III hierarchy. Thus the appellate court must apply the new law to Nina's nonfinal case. (Derived from Plaut v. Spendthrift Farm, Inc. (1995).)