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A Broader Scope For American Pipe Tolling Doctrine

Law360 (November 11, 2008, 12:00 AM EST) -- On Sept. 12, 2008, in State Farm Mutual Automobile Insurance Co. v. Boellstorff, the U.S. Court of Appeals for the Tenth Circuit held that the class action tolling doctrine established by the U.S. Supreme Court in American Pipe & Construction Company v. Utah[1] applies when an individual member of a putative class action pursues an independent claim, otherwise time-barred, before the issue of class certification has been decided.[2]

In ruling the class action tolling doctrine allows a litigant to file an individual suit before the class...
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