In Collins v. Village of Palatine, Illinois, No. 16-3395 (7th Cir. Nov. 16, 2017), the Seventh Circuit addressed the intricacies of the American Pipe doctrine. That case provides that when plaintiff files a complaint on behalf of a class, the statute of limitations for each member of the class is tolled until “the case is ‘stripped of its character as a class action.’” This “stripping” occurs when the district court denies class certification, dismisses the case for lack of subject matter jurisdiction, or otherwise dismisses the case without prejudice. In Collins, the Seventh Circuit held that a dismissal with prejudice also strips the case of its class action character. The court adopted a “simple and uniform rule: Tolling stops immediately when a class action suit is dismissed – with or without prejudice – before the class is certified.” The Court considered whether a district court’s dismissal of a prior lawsuit tolled the limitations period, or whether tolling continued until the dismissal was affirmed and certiorari denied. The Seventh Circuit found the statute of limitations was not tolled during the period from the district court’s dismissal until the Supreme Court denied certiorari. The Court relied on cases in other contexts that established the consensus view that “once certification is denied, the limitations clock immediately starts ticking again.” In Collins, the Seventh Circuit applied that reasoning to the dismissal with prejudice of the underlying claim, even if certification had not yet been sought or obtained.