Enbridge Energy, LP v. Nessel
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Enbridge Energy, LP v. Nessel and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Enbridge Energy, LP v. Nessel.
The Supreme Court addressed whether the 30-day removal deadline under 28 U.S.C. §1446(b)(1) is subject to equitable tolling. The Court found that the text, structure, and context of §1446(b)(1) indicate that Congress did not intend for equitable tolling to apply. Consequently, Enbridge's removal of the case to federal court was deemed untimely.
Holding
The single most important “bottom line” of what the Court decided in Enbridge Energy, LP v. Nessel.
The Court held that §1446(b)(1)'s text, structure, and context are inconsistent with equitable tolling, making Enbridge's removal untimely.
Constitutional Concepts
These are the Constitution-related themes that appear in Enbridge Energy, LP v. Nessel. Click a concept to see other cases that involve the same idea.
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Why Procedural Due Process is relevant to Enbridge Energy, LP v. Nessel
The case involves the procedural aspect of removal deadlines and whether equitable tolling applies, which relates to fair legal procedures.
Syllabus excerpt (verbatim)The District Court denied the motion, holding that equitable principles justified excusing Enbridge’s untimely removal, and certified its order for interlocutory appeal.
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Why State–Federal Power is relevant to Enbridge Energy, LP v. Nessel
The case concerns the allocation of authority between state and federal courts regarding the removal of cases, implicating state-federal power dynamics.
Syllabus excerpt (verbatim)This Court granted certiorari to resolve a divide among the Courts of Appeals on whether §1446(b)(1) is subject to equitable tolling.
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Why Preemption is relevant to Enbridge Energy, LP v. Nessel
The case involves federal removal statutes potentially preempting state court jurisdiction, which is a form of preemption.
Syllabus excerpt (verbatim)The federal civil removal statutes have an 'obvious concern with efficiency,' BP p.l.c. v. Mayor and City Council of Baltimore, 593 U. S. 230, 245.
Key Quotes
Short excerpts from the syllabus in Enbridge Energy, LP v. Nessel that support the summary and concepts above.
The text of §1446(b)(1) speaks in strict, mandatory terms.
Congress’s manifest interest in resolving threshold removal questions early and conclusively.
Congress did not want the 30-day deadline to be equitably tolled.