Plaut v. Spendthrift Farm, Inc.
United States Supreme Court
514 U.S. 211 (1995)
Ed Plaut and other Spendthrift Farm shareholders (plaintiffs) sued Spendthrift Farm (defendant) over stock sales they claimed violated federal securities law, but after the Supreme Court established a new statute of limitations for such claims in 1991, the district court dismissed their suit as untimely. Congress then passed the FDIC Improvement Act later that year, requiring courts to reinstate cases dismissed under that newly established limitations period; when the shareholders moved to reinstate their case, the district court denied the motion, holding the Act itself unconstitutional as a violation of separation of powers, and the Sixth Circuit affirmed on the same ground.
Whether Congress violates the constitutional separation of powers by requiring federal courts to reopen cases that have already received final judgments.