Lloyd Cramer’s Empirical Analysis
2001
Citation profile
13 district · 14 state decisions
How this case has been cited
Cited by 96 later decisions — most recently January 2022 · most notably 121 Cal. App. 4th 623 - Haney v. Aramark Uniform Services, Inc. (2004), No. 04-57134 (2007)
13 district · 14 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 Franchise Tax Board of the State of California v. Construction Laborers Vacation Trust for Southern California · Caterpillar Inc. v. Williams · Textile Workers v. Lincoln Mills of Ala. · Allis-Chalmers Corp. v. Lueck · Lingle v. Norge Division of Magic Chef, 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 96 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[t]he plaintiff's claim is the touchstone for this analysis; the need to interpret the CBA must inhere in the nature of the plaintiff's claim.”
6 later decisions quote this exact passage · from the majority““To the extent our prior cases held or implied that preemption was proper because of the mere possibility that the subject matter of the claim was a proper subject of the collective bargaining process, whether or not specifically discussed in the CBA, we today hold such statements to be an incorrect articulation of § 301 preemption principles. A state law claim is not preempted under § 301 unless it necessarily requires the court to interpret an existing provision of a CBA that can reasonably be said to be relevant to the resolution of the dispute.” Id. at 693.”
3 later decisions quote this exact passage · from the majority“It is true that when a defense to a state claim is based on the terms of a[CBA], the state court will have to interpret that agreement to decide whether the state claim survives. But the presence of ... a § 301 question, in a defensive argument does not overcome the paramount policies embodied in the well-pleaded complaint rule-that the plaintiff is the master of the complaint, that a federal question must appear on the face of the complaint, and that the plaintiff may, by eschewing claims based on federal law, choose to have the cause heard in state court ... a defendant cannot, merely by injecting a federal question into an action that asserts what is plainly a state-law claim, transform the action into one arising under federal law, thereby selecting the forum in which the claim shall be litigated.”
2 later decisions 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.