Rachel Reynolds Publishes FRCP Article for FDCC

March 13, 2019

Seattle Partner Rachel Tallon Reynolds recently published an article for the Federation of Defense and Corporate Counsel’s (FDCC) e-newsletter regarding the application of Federal Rule of Civil Procedure 23(f) in a recent Supreme Court case. The article, titled “For Whom the Rule Tolls: Rule 23(f) Not Subject to Equitable Tolling,” was featured in the e-newsletter’s Class Action & Multidistrict Litigation (MDL) Practice Section.

Seattle, Wash. (March 13, 2019) – Seattle Partner Rachel Tallon Reynolds recently published an article for the Federation of Defense and Corporate Counsel’s (FDCC) e-newsletter regarding the application of Federal Rule of Civil Procedure 23(f) in a recent Supreme Court case. The article, titled “For Whom the Rule Tolls: Rule 23(f) Not Subject to Equitable Tolling,” was featured in the e-newsletter’s Class Action & Multidistrict Litigation (MDL) Practice Section.

In the article, Ms. Reynolds explains how the Supreme Court applied the text of Rule 23(f) to reverse a Ninth Circuit decision in Neutraceutical Corp. v. Troy Lambert, which involved the appeal of a class decertification order. In a unanimous decision, the Court held that Rule 23(f) is not subject to equitable tolling, clarifying any confusion about the practical application of the timeline for this type of appeal. Ms. Reynolds’ article summarizes the Court’s reasoning and gives advice to litigants considering a Rule 23(f) appeal.

The FDCC is a peer-selected organization dedicated to promoting knowledge, fellowship, and professionalism with the legal defense community. Ms. Reynolds currently serves as a vice-chair of its Class Action and MDL Committee, and is a member of its Admissions and Toxic Torts Committees. A member of Lewis Brisbois’ Toxic Tort & Environmental Litigation, Products Liability, and General Liability Practices, Ms. Reynolds is also currently the President-Elect of the Washington Defense Trial Attorneys.

Read Ms. Reynolds’ full article here.