This Comment discusses to what extent the commencement of a class suit tolls the statute of limitations for the benefit of unnamed or absent members of the class who would have been barred by the statute of limitations from instituting their own individual suits. American Pipe & Construction Co. v. Utah is a recent United States Supreme Court decision that recites and establishes a confluent rationale for tolling the statute of limitations, under purportedly limited and narrow circumstances, for the benefit of all asserted members of the class upon the commencement of the class suit.
Douglas C. Holland,
Under the Portcullis and Inside the Golden Castle: American Pipe & Construction Co. v. Utah,
San Diego L. Rev.
Available at: https://digital.sandiego.edu/sdlr/vol12/iss1/8