ASUNCION V. HEGSETH

9th CircuitSep 4, 2025

Split Score

SplitScore: 44/100

Case Summary

Disposition

Reversed

The Ninth Circuit reversed the district court’s dismissal of Rodolfo T. Asuncion, Jr.’s Rehabilitation Act suit, holding that the 90-day statute of limitations for filing a civil action did not begin until Asuncion’s attorney actually received an accessible, decrypted copy of the final agency decision. The court alternatively found equitable tolling warranted because the agency’s repeated transmission errors constituted extraordinary circumstances despite diligent efforts by counsel.

Circuit Split Identified

Legal Issue

When electronically transmitted notice of a final agency decision/right-to-sue letter triggers the 90-day filing period for Title VII/Rehabilitation Act actions.

Circuit Positions

7th Circuit8th Circuit

90-day period begins upon initial electronic notification containing a link or encrypted attachment, regardless of actual ability to open the document.

1st Circuit9th Circuit(this circuit)

90-day period begins only when the claimant or counsel has effective access to the decision or receives an email that unambiguously conveys the final decision and the 90-day deadline.

Conflict Summary

The Seventh and Eighth Circuits start the 90-day period when the claimant receives an email containing a link or encrypted attachment to the decision, even if the claimant cannot yet open it. The First and Ninth Circuits require that the claimant or counsel have effective access to the contents of the decision (or an email that unambiguously conveys the final decision and 90-day deadline) before the limitations period begins.

Parties & Counsel

Parties

Appellant:Rodolfo T. Asuncion, Jr.
Appellee:Peter Hegseth, in his official capacity as Secretary of Defense

Legal Counsel

Appellant:Law Office of Shawn A. Luiz, Honolulu, Hawaii
Appellee:Office of the United States Attorney, United States Department of Justice, Honolulu, Hawaii (Tracy J. Weinstein, Sydney Spector, Clare E. Conners)

Opinion Document