1. Rule 3 does not specify the purposes for which an action is commenced. Two arguments were thus available for the Court in Walker to find that Rule 3 did not operate to toll the Oklahoma statute of limitations. First, the Court could have held that Rule 3 applies only to time requirements in other Federal Rules of Civil Procedure, tolling neither state nor federal statutes of limitations. Alternatively, the Court could have found that Rule 3 tolls federal but not state statutes of limitations.

Which argument is more persuasive? Which argument does the Court make in Walker?

Note that there was abundant authority, cited in footnote 9 in Walker of the Court’s opinion

(including a dictum in Ragan), suggesting that Rule 3 does operate to toll federal statutes of limitations. Walker reserved this question, holding that, even if Rule 3 governs federal statutes of limitations, it does not apply to state statutes. But if Rule 3 does not toll federal statutes of limitations, what does?

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