1. This case presents an important and recurring question regarding how courts should resolve ambiguity as to the scope of a putative or certified class in determining whether a plaintiffs claims have been equitably tolled under American Pipe & Construction Co. v. Utah, 414 U.S. 538 (1974). Under American Pipe, the claims of individual parties included in the definition of a putative class are tolled during the pendency of the class action proceedings. After the class is denied certification or is decertified, individuals whose claims were tolled may bring their own claims during any time that remains within the previously tolled limitations period. The decision below broke from the Eleventh Circuit's rule that parties seeking to benefit from American Pipe tolling bear the burden of showing that they were unambiguously included within the scope of the definition of the putative class. The Fifth Circuit instead held that an individual plaintiff bringing a successive action benefits from American Pipe tolling unless the defendant can demonstrate that the putative class definition "unambiguously excludel[d]" the plaintiff.

Whether a plaintiff seeking to benefit from American Pipe tolling must definitively demonstrate inclusion in a previously decertified class definition, or whether the burden is on the defendant to prove the plaintiff was unambiguously excluded