Malia’s Empirical Analysis
Citation profile
1 federal appellate · 4 district ·
How this case has been cited
Cited by 39 later decisions (2 by the Supreme Court) — most recently April 2019 · most notably Beck v. Pace International Union (2007), End of the Road Trust Ex Rel. Fruehauf Trailer Corp. v. Terex Corp. (In Re Fruehauf Trailer Corp.) (2000)
1 federal appellate · 4 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
Relies on Markowitz v. Northeast Land Co. · Unger v. National Residents Matching Program · Van Orman v. American Insurance · Hlinka v. Bethlehem Steel Corp. · Johnson v. Georgia-Pacific Corp.
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 39 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“§§ 208 and 4044(d)(3) [of ERISA, 29 U.S.C. §§ 1058 , 1344(d)(3)] cannot be combined to provide [defined benefit] plan participants with a right to residual assets in the context of a plan merger. The district court correctly granted appellees’ [Rule 12(b)(6)] motion to dismiss on this claim.” Malia, 23 F.3d at 833 ; see also Borst v. Chevron Corp., 36 F.3d 1308 , 1316 (5th Cir.1994) (”
2 later decisions quote this exact passage · from the majority“are elements that are conceptualized and treated differently in a plan termination than are”
2 later decisions quote this exact passage · from the majoritye.g. 22 Employee Benefits Cas. 2717, Pens. Plan Guide (Cch) P 23952o Steven W. Bennett Edmund L. Gillooley Joseph L. Alessandrini, Jr. Frank W. Hewitt Richard E. Semarad Warren E. Kaylor, Individually and on Behalf of All Others Similarly Situated v. Conrail Matched Savings Plan Administrative Committee Deborah A. Melnyk John/jane Does 1-10 Consolidated Rail Corporation Matched Savings Plan, Steven W. Bennett Edmund L. Gillooley Joseph L. Alessandrini, Jr. Frank W. Hewitt Richard E. Semarad Warren E. Kaylor, Individually and on Behalf of All Members of the Proposed Class, in 97-1916. Joanne Kelly, Individually and on Behalf of All Others Similarly Situated v. Conrail Matched Savings Plan Administrative Committee Deborah A. Melnyk John/jane Does 1-10 Consolidated Rail Corporation Matched Savings Plan, Joanne Kelly, in 97-1917. George E. Gale, Iii, Individually and on Behalf of All Others Similarly Situated, 97-1918 v. Conrail Matched Savings Plan Administrative Committee Deborah A. Melnyk John/jane Does 1-10 Consolidated Rail Corporation Matched Savings Plan · 23952o Bennett“[ejfforts by an employer to merge two pension plans do not invoke the fiduciary duty provisions of ERISA. Such duties do not attach to business decisions related to modification of the design of a pension plan, and in such circumstances the plan sponsor is free to act “as an employer and not a fiduciary.””
1 later decision quote this exact passage · from the concurrence
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.