Plaut v. Spendthrift Farm, Inc

Brief Fact Summary. The Plaintiff – Petitioner, Plaut (Petitioner), sued the Defendant –
Respondent, Spendthrift Farm (Respondent), under Section: 10 of the Securities Exchange Act of 1934 (the Act). The suit was dismissed for not being filed in a timely fashion.

Synopsis of Rule of Law. Congress may not require the federal courts to reopen a case after a court has rendered final judgment.

Facts. In 1991, the Supreme Court of the United States (Supreme Court) ruled that actions brought under Section: 10(b) and Rule 10(b)(5) of the Act must be brought within one year of discovering the facts leading to the violation and within three years of the violation itself. In response, Congress amended the law to allow cases filed before the decision to go forward, if they could have been brought under the previous law. Petitioner had brought suit prior to the decision, but the suit was dismissed in accordance with the Supreme Court’s ruling. Petitioner attempted to resume prosecution of the dismissed case.

Issue. May Congress require Article III courts to reopen cases on which they have passed judgment?

Held. No. Appeals court ruling affirmed.
Congress may pass retroactive legislation that affects cases still pending appeal. However, this amendment requires cases to resume prosecution after judgment has been rendered.
A judgment “conclusively resolves the case.” The statute in question offends this postulate.

Discussion. Justice Antonin Scalia (J. Scalia) argues Congress has violated the separation of the judicial and legislative powers, by requiring courts to set aside final judgments, which the framers of the constitution envisioned as dispositive.