Introduction

TRW Inc. v. Andrews is a significant U.S. Supreme Court decision that clarifies the interpretation of the statute of limitations under the Fair Credit Reporting Act (FCRA). Decided on November 13, 2001, this case addresses whether a general discovery rule applies to the FCRA's two-year limitation period for enforcing liability, particularly in cases of identity theft and improper disclosure of credit information.

Summary of the Judgment

The Supreme Court reversed the Ninth Circuit Court of Appeals' decision, holding that § 1681p of the FCRA does not incorporate a general discovery rule. Instead, the two-year statute of limitations begins to run from the date the liability arises, unless there is a willful misrepresentation by the defendant, in which case the limitation period is extended to two years after the plaintiff discovers the misrepresentation.

In this case, Adelaide Andrews discovered that her credit information had been improperly disclosed by TRW Inc. more than two years after the initial violations occurred. She sued TRW for violations of the FCRA. TRW argued that the claims based on the first two disclosures were time-barred, but Andrews contended that the limitations period should start from her discovery of the violations. The District Court agreed with TRW, but the Ninth Circuit disagreed, applying a general discovery rule. The Supreme Court ultimately sided with TRW, emphasizing the specific exception outlined in § 1681p rather than adopting a broader discovery rule.

Analysis

Precedents Cited

The Supreme Court discussed several key precedents in its decision:

• HOLMBERG v. ARMBRECHT, 327 U.S. 392 (1946): Established that statutes of limitations are tolled in cases of fraud or concealment until the fraud is discovered.
• ROTELLA v. WOOD, 528 U.S. 549 (2000): Recognized a discovery rule in the context of latent diseases and medical malpractice.
• Bay Area Laundry & Dry Cleaning Pension Trust Fund v. Ferbar Corp. of Cal., 522 U.S. 192 (1997): Reaffirmed the traditional rule that the statute of limitations begins when the cause of action is complete, not when it is discovered.
• URIE v. THOMPSON, 337 U.S. 163 (1949): Addressed the application of the discovery rule in the context of the Federal Employers' Liability Act.

The Court clarified that while these precedents acknowledge exceptions to the traditional rule, they do not support a broad application of the discovery rule across all federal statutes.

Legal Reasoning

The Court emphasized the importance of adhering to the specific language and structure of the FCRA. § 1681p explicitly outlines a general two-year limitation period starting from when the liability arises, with a specific exception only for willful misrepresentation of material information. The Court reasoned that introducing a general discovery rule would undermine the express statutory language and render the exception nearly meaningless.

Justice Ginsburg, delivering the opinion of the Court, argued that Congress intended to limit the statute of limitations in the FCRA to the scenarios explicitly described in § 1681p. The Court rejected the Ninth Circuit's broader interpretation, stating that the statute does not implicitly authorize a general discovery rule. Furthermore, the Court highlighted that applying a general discovery rule would not align with the legislative intent and could lead to inconsistencies in the application of the law.

Impact

This judgment reinforces the principle that specific statutory language governs the interpretation of limitations periods. For cases under the FCRA, it means that plaintiffs cannot rely on a general discovery rule to extend the two-year limitation period unless their claims fall within the narrowly defined exception of willful misrepresentation.

Future litigants must be diligent in filing claims within two years of the liability arising, as defined by the statute, rather than waiting until they discover the harm. This decision limits the flexibility that courts might otherwise have in interpreting statutes of limitations and underscores the necessity for clear legislative drafting.

Complex Concepts Simplified

Conclusion

The Supreme Court's decision in TRW Inc. v. Andrews underscores the importance of specific statutory language over general legal principles like the discovery rule. By upholding the limitations period as starting from when the liability arises, the Court ensures that the FCRA's provisions are applied as Congress intended. This ruling emphasizes the need for clear legislative drafting and limits judicial interpretation from expanding beyond the express terms of the law.