Joseph O'Connor Peter Horning v. Commonwealth Gas Company John Williams Commonwealth Energy System and William Poist Joseph O'Connor Peter Horning’s Empirical Analysis
251 F.3d 262 · 2001
Citation profile
2 federal appellate · 27 district · 2 state decisions
How this case has been cited
Cited by 38 later decisions — most recently June 2020 · most notably Ritter v. Massachusetts Casualty Insurance (2003), Balestracci v. NSTAR Electric & Gas Corp. (2006)
2 federal appellate · 27 district · 2 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
Relies on United Mine Workers of America v. Gibbs · Fort Halifax Packing Co. v. Coyne · Chardon v. Fernandez · Massachusetts v. Morash · Rodriguez v. Doral Mortgage 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 38 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“the nature and extent of an employer’s benefit obligations. Those obligations are the touchstone of the determination: if they require an ongoing administrative scheme that is subject to mismanagement, then they will more likely constitute an ERISA plan; but if the benefit obligations are merely a one-shot, take-it-or-leave-it incentive, they are less likely to be covered.”
3 later decisions quote this exact passage · from the majority“Courts generally decline to exercise supplemental jurisdiction over state claims 3Given the resolution of the PMPA claim, the court does not consider the plaintiffs' allegation of anti-Arab discrimination. if the federal predicate is dismissed early in the litigation.”
2 later decisions quote this exact passage · from the majority“[t]he “Severance Plan” consists of a ... lump-sum severance, the centerpiece of the incentive, plus a few enhanced benefits that otherwise would have been provided upon retirement under pre-existing ERISA plans, though without the added inducement ... of COBRA premiums for a year. Although ... these non-severance benefits might implicate ERISA to some extent, we are persuaded that they did not transform the [Severance Plan] as a whole into an ERISA-protected plan. These were minor perks attached to the severance. Neither involved the kind of ongoing discretionary judgments that would sufficiently tax an employer’s administrative integrity to warrant ERISA’s prophylaxis”
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.