William Prazak v. Local 1 International Union of Bricklayers & Allied Craftswilliam C. Wolter the Stebbins Engineering & Manufacturing Co. Larry R. Stenstrom Hensen Masonry & Equipment Co., Inc.
Docket: 98-36129
Court: Court of Appeals for the Ninth Circuit; November 12, 2000; Federal Appellate Court
William Prazak appealed the district court's summary judgment favoring the Local 1 International Union of Bricklayers and other defendants, who argued that Prazak's complaint was barred by the six-month federal statute of limitations. Prazak had initially filed a lawsuit in Alaska Superior Court in 1991 for hiring hall and collective bargaining violations, which was later dismissed for failure to prosecute but subsequently reinstated by the Alaska Supreme Court. After multiple procedural developments, including a dismissal without prejudice in 1997, Prazak refiled his complaint in 1998. The union removed the case to federal court and sought summary judgment based on the statute of limitations. The district court ruled that Prazak's refiled complaint did not comply with the federal statute.
The Ninth Circuit addressed whether state procedural rules apply in federal question cases that begin in state court despite the federal six-month limitation. The court held that if a plaintiff initially complies with the federal statute of limitations, state procedural rules remain applicable until the case is removed to federal court. Prazak's claim is categorized as a "hybrid" claim, involving allegations against both employers and the union under the Labor Management Relations Act and the National Labor Relations Act. The ruling draws on precedents set by DelCostello v. International Brotherhood of Teamsters, which established that a six-month statute of limitations is appropriate for hybrid claims to ensure employees can adequately vindicate their rights. The Court reversed the district court’s decision, allowing Prazak's appeal to proceed.
The holding emphasizes that the decision does not deviate from existing practices regarding borrowing state limitations periods for federal causes of action. Federal courts are encouraged to utilize state limitations periods even when state law does not perfectly align with federal claims, as finding a suitable state law analogy is not always straightforward.
In West v. Conrail, the Supreme Court clarified that its earlier decision in DelCostello only addressed the appropriate limitations period and did not alter the Federal Rules of Civil Procedure. The Court asserted that actions based on federal law are not barred if they are commenced in compliance with Rule 3 within the borrowed limitations period. Furthermore, it noted that the requirements for service within a limitations period apply when the underlying cause of action is based on state law, not federal law.
Under Alaska law, if a case is initiated within the prescribed time but dismissed, a new action may be filed within one year after dismissal. This statute applies even to cases dismissed for failure to prosecute, as confirmed by the Alaska Supreme Court.
Prazak's situation is distinct from DelCostello and West because his hybrid claim was initially filed in state court. He filed a complaint on August 2, 1991, within the six-month limitation, and after his case was dismissed without prejudice on July 11, 1997, he refiled on May 22, 1998, adhering to Alaska’s one-year refiling statute. The district court's dismissal of Prazak's refiled complaint for noncompliance with DelCostello was deemed erroneous. Generally, state procedural rules govern cases in state court until they are removed to federal court, where the Federal Rules of Civil Procedure then apply only to procedures following removal.
The legal document highlights a division among circuits regarding the application of state procedural rules to hybrid cases. Specifically, it contrasts the decisions in Winkels and Gorwin, which support applying state rules while the case is in state court, with Cannon, where the Fourth Circuit rejected this application. In Cannon, the plaintiff's action was initiated in state court, but after a delay in filing the complaint, the case was removed to federal court and dismissed as time-barred. The Fourth Circuit's majority opinion argued that allowing state rules would compromise uniformity in procedural matters.
Conversely, dissenting Judge Murnaghan contended that applying state rules does not undermine uniformity goals, asserting that state procedural rules should govern cases initially filed in state courts, even when they involve federal causes of action. He highlighted that the initial appearance in state court satisfied the statute of limitations and criticized the majority for misinterpreting the implications of DelCostello and West. Murnaghan's view was supported by referencing Herb v. Pitcairn, which emphasizes that federal procedural rules apply post-removal from state court.
The Eighth Circuit's decision in Winkels aligned with Murnaghan's dissent, ruling that state procedural rules govern hybrid suits from state court origin. Winkels overturned a dismissal, citing that federal procedural rules do not supersede state rules in such cases, thus maintaining the integrity of the six-month statute of limitations without undermining the Supreme Court's uniformity principles as articulated in DelCostello.
Judge Sotomayor's decision in Gorwin v. Local 282, I.B.T. established that when a hybrid action is initiated in state court, federal rules do not automatically displace state rules. In Gorwin, the plaintiff's initial state action was dismissed for lack of service but was refiled within the state’s allowed timeframe of 120 days. The court found the original lawsuit complied with the six-month statute of limitations set by DelCostello. The current case reverses the district court's summary judgment in favor of the appellees, aligning with the Eighth Circuit, Judge Murnaghan's dissent, and Judge Sotomayor's reasoning. It asserts that Prazak initially met the timing requirements of DelCostello, that the rulings in DelCostello and West are limited in scope, and that state procedural rules govern state court lawsuits. The reversal does not conflict with the Supreme Court's holdings, as it maintains that hybrid-claim defendants seeking federal procedural benefits should file in federal court. The distinction with Beck v. Caterpillar is noted, emphasizing that Beck involved a federal court origin and different circumstances, thus not applicable to this case.
