Hemelt’s Empirical Analysis
Citation profile
2 district · 3 state decisions
How this case has been cited
Cited by 18 later decisions — most recently December 2016
2 district · 3 state decisions
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 26 U.S.C. § 104 · 26 U.S.C. § 3121 (Federal Insurance Contributions Act)
Relies on Massachusetts Mutual Life Insurance v. Russell · Mertens v. Hewitt Associates · Harper v. Virginia Department of Taxation · James B. Beam Distilling Co. v. Georgia · Rivers v. Roadway Express, Inc.
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 18 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The method used to calculate the awards here further supports the view that the settlement payments are properly characterized as wages. The two components of the settlement awards were based directly on taxpayers' employment relationship with Continental; key factors in determining the amounts of each award were the length of each employee's tenure with Continental and the salary he received from Continental. Thus, because the payments from Continental to taxpayers and other class members arose out of their employment relationship, they fit within the statutory and regulatory definition of wages, and FICA taxes were properly withheld from the awards.”
2 later decisions quote this exact passage · from the concurrence“the case is no longer 'open on direct review' " so that the majority may somehow avoid application of Mertens contrary to Hemelt, Mayberry, and the dissenter in Dotson. 61 Mayberry and Hemelt point out that many of the circuits had held at the time of the Continental Can settlement that such damages, claimed to be personal injury damages, were not available under ERISA. Hemelt affirmed the decision of the district court, which also disagreed with the decision of the Dotson majority. Chief Judge Wilkinson in Hemelt concluded that the payments in question were essentially wages, relying on Mertens and Burke, and characterized what plaintiffs received as a "substantial benefit to which they were not entitled under law, namely the award of large sums of money for emotional and intangible injuries that ERISA section 502 does not compensate.”
1 later decision quote this exact passage · from the concurrence“The Mertens Court further concluded that an expansive interpretation of section 502(a)(3) to include money damages would distort the statute by giving the term 'equitable relief a different meaning in section 502(a)(3) than it bears elsewhere in ERISA.” (internal quotation marks omitted)). Furthermore, in Defendants’ first Motion to Dismiss, Defendants argued Plaintiff was seeking relief under section 502(a)(3) for Defendants’ alleged failure to comply with ERISA's claims procedure requirements. (Defendants’ Mot. to Dismiss at 11.) Defendants state,”
1 later decision quote this exact passage
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.