Task: Wrong Candidate Generation
Input (English): F.3d 310, 320 (3d Cir.2001), overruled on other grounds by Carey v. Saffold, 536 U.S. 214, 122 S.Ct. 2134, 153 L.Ed.2d 260 (2002) (mental incompetence may warrant equitable tolling where alleged mental incompetence has affected petitioner’s ability to timely file); State v. Nix, 40 S.W.3d 459 (Tenn.2001) (due process requires tolling of PCR statute of limitations only if petitioner is unable to manage his affairs or understand his legal rights and liabilities); Seals v. Tennessee, 23 S.W.3d 272, 277 (Tenn.2000) (due process considerations may toll statute of limitations if mentally incompetent petitioner was denied the opportunity to bring a claim in a “meaningful time and manner”). But see Allen v. State, — So.2d - (Miss.App.2008), citing House v. State, 754 So.2d 1147 (Miss. 1999) (<HOLDING>). Although we have not specifically addressed 
 Holding statements: (A) holding there is no authority to toll statute of limitations based on mental incompetence (B) holding petition for writ of mandate seeking return of property does not toll the statute of limitations (C) holding that duress toll to statute of limitations under state law had no application to federal rico statute of limitations (D) holding that under the law of the district of columbia the filing of a complaint does not toll the statute of limitations on a counterclaim (E) holding that the concealment of ones identity does not toll the running of the statute of limitations
Output (English): holding that under the law of the district of columbia the filing of a complaint does not toll the statute of limitations on a counterclaim