When an action is initially brought in a state or federal court and is dismissed for lack of proper venue or jurisdiction, it frequently becomes necessary to determine whether the applicable statute of limitations has been tolled ,during the pendency of the action. If a second action is instituted after the "statutehas run, the action will be considered time-barred in the absence of a tolling doctrine.
The Tolling of the Statute of Limitations When A Case Has Been Previously Dismissed for Lack of Jurisdiction or for Improper Venue,
U. Rich. L. Rev.
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