State Farm Mutual Automobile Insurance Company, Farmers Insurance Exchange v. Roger Ammann

Summary

The Ninth Circuit reversed and remanded summary judgment in a civil RICO action brought by State Farm and Farmers concerning false insurance claims. The court held that the district court applied the wrong three-year limitations period because the Supreme Court had established a uniform four-year period, and directed reconsideration under the applicable accrual rule.

Holdings

1. Civil RICO claims are governed by a uniform four-year statute of limitations, not the three-year period applied by the district court.
2. As to each injury, the civil RICO limitations period begins when the plaintiff knows or has reason to know of the injury that forms the basis of the action.

Questions Presented

1. Whether the district court applied the correct limitations period to the plaintiffs' civil RICO claims.
2. When the civil RICO limitations period begins to run for each injury.

Disposition

reversed_and_remanded