The following excerpt is from Cruz v. Int'l Collection Corp., 673 F.3d 991 (9th Cir. 2012):
7 Some statutes of limitations are jurisdictional. See, e.g. Adams v. United States, 658 F.3d 928, 933 (9th Cir.2011) (holding that the Federal Tort Claims Act's six month statute of limitations is jurisdictional). FRCP 15(c)(1)(A) provides for such statutes by holding that relation back is permitted only when "the law that provides the applicable statute of limitations allows relation back."
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