Spinelli v. Gaughan’s Empirical Analysis
12 F.3d 853 · 1993
Citation profile
33 federal appellate · 8 district ·
How this case has been cited
Cited by 67 later decisions — most recently May 2018 · most notably Parino v. Fhp, Inc., Festo Corporation v. Shoketsu Kinzoku Kogyo Kabushiki Co Ltd Smc Corporation Smc Pneumatics Inc (2000)
33 federal appellate · 8 district ·
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Applies 28 U.S.C. § 1491 · 29 U.S.C. § 1132 (§ 502 of the Employee Retirement Income Security Act of 1974) · 29 U.S.C. § 1140 (§ 510 of the Employee Retirement Income Security Act of 1974)
Relies on Pilot Life Insurance v. Dedeaux · Ingersoll-Rand Co. v. McClendon · Granfinanciera, S.A. v. Nordberg · Mertens v. Hewitt Associates · Curtis v. Loether
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 67 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[Njothing in ... the Seventh Amendment, or anywhere else [ ] prevents Congress from creating a cause of action for which only equitable relief is available .... The rights and remedies provided under ERISA are not merely a repackaging of existing rights. The right of an employee not to be discharged for exercising rights under ERISA has no precursor under federal law; the Seventh Amendment does not speak to whether a new cause of action must be legal or equitable. Insofar as section 510 displaces existing rights available under state law — as it well may — it does not merely relabel those rights by calling them equitable while leaving in place their essentially legal character. By limiting the remedies to those available in equity, Congress has changed what the dispute is about. Damages, which are the heart of many civil disputes, have been made unavailable. Instead, the plaintiff may obtain only those more flexible and discretionary remedies available to a court of equity. Mertens, 508 U.S. at 257 , 113 S.Ct. at 2069 . This is far more than a cosmetic change and the Seventh Amendment does not stand in the way. [Plaintiff] also argues that Congress may not take away a plaintiffs legal claim under state law and replace it with a federal claim that is only equitable in nature. But we fail to see any constitutional impediment to such action. Congress surely can preempt a state cause of action, be it legal or equitable: This is the very nature of federal supremacy. Once Congress ”
5 later decisions quote this exact passage · from the majority“[h]aving done so, . . . created a right that is essentially equitable in nature”
2 later decisions quote this exact passage · from the majority“We get a different answer ... in considering the nature of the remedy provided. By its terms, section 502 — the remedies provision for section 510 — provides only for equitable relief. Thus Subsection (A) speaks exclusively about enjoining any practice which violates ERISA, 29 U.S.C. § 1132 (a)(3)(A): Subsection (B) is even more explicit, providing only for ‘other appropriate equitable relief,’ 29 U.S.C. § 1132 (a)(3)(B). The language is clear enough, but the Supreme Court last term removed any remaining doubt in Mertens v. Hewitt Assocs. , — U.S.-, -, 113 S.Ct. 2063, 2069 , 124 L.Ed.2d 161 (1993), which holds that damages are not available for a violation of section 502(a)(3).”
1 later decision quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.