Sebelius v. Auburn Regional Medical Center (2012)
- Docket
- 11-1231
- Decided
- 2012-01-01
Summary
Question: Is the statute of limitations for filing a claim with the PRRB for Medicare payments subject to tolling for good cause? Conclusion: Yes, but only up to 3 years. Justice Ruth Bader Ginsburg, writing for a unanimous court, reversed the lower court and remanded. The Supreme Court held that the 180-day statute of limitations is not "jurisdictional" so it may be extended in some cases. Unless Congress has clearly stated that a statutory limitation is jurisdictional it is presumed to be non-jurisdictional. The Secretary of Health and Human Services regulation allowing a 3-year extension for good cause was permissible, as courts must defer to agency regulations unless they are "arbitrary, capricious, or manifestly contrary to the statute." The general presumption in favor of equitable tolling does not apply to an agency's internal deadline, absent evidence of congressional intent, so the Court could not extend the deadline indefinitely. Justice Sonia Sotomayor concurred, noting that the majority's opinion does not establish that equitable tolling is never applicable to internal administrative deadlines.