Although he is remembered as a Los Angeles Laker, Hall of Famer Kareem Abdul-Jabbar, as basketball trivia buffs know, actually began his NBA career on the Milwaukee Bucks. After turning down an offer to play for the Harlem Globetrotters, Abdul-Jabbar was drafted by the Bucks in 1969, where he won the MVP in his second season while leading the Bucks to their sole NBA championship in 1970. In October 1974, Abdul-Jabbar requested a trade to Los Angeles, and the rest (including his role as Roger Murdock in Airplane!) is history.
1974 was also a monumental year with regard to class-action tolling. In American Pipe & Constr. Co. v. Utah, 414 U.S. 538 (1974), the Supreme Court held that the timely filing of a class-action tolls the applicable statute of limitations for all persons encompassed by the class complaint. Where class action status is denied, the Court ruled that members of the failed class could timely intervene as individual plaintiffs in the still-pending, non-class action, even though it had been divested of its class character. The question before the Court in China Agritech, Inc. v. Resh, Case No. 17-432 (June 11, 2018), was the natural extension of that decision: When class certification is denied, may a putative class member, in lieu of promptly joining an existing suit or promptly filing an individual action, commence a class action anew, beyond the time allowed by the applicable statute of limitations? Justice Ginsburg delivered the unanimous opinion: “Our answer is no.”