The U.S. Supreme Court has denied a request to review the Federal Circuit’s determination that the National Childhood Vaccine Injury Compensation Act’s statute of limitations cannot be tolled by the discovery rule. Cloer v. Sebelius, No. 11-832 (U.S., certioriari denied April 16, 2012). Additional details about the case appear in the August 25, 2011, issue of this Report. Although the Federal Circuit ruled that the Act does not contain a discovery rule “that would key the accrual of a non-Table injury and the beginning of the statute of limitations to a claimant’s discovery that the vaccine caused her injury” and that the discovery rule cannot be read by implication into the law’s statute of limitations, it also concluded that equitable tolling applies under the Act.