Mitchell v. Chapman’s Empirical Analysis
343 F.3d 811 · 2003
Citation profile
27 federal appellate · 13 district · 3 state decisions
How this case has been cited
Cited by 124 later decisions (2 by the Supreme Court) — most recently April 2023 · most notably 14 Penn Plaza LLC v. Pyett (2009), Dixon v. Gonzales (2007)
27 federal appellate · 13 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.
Appellate journey
Relationships
Applies 29 U.S.C. § 203 · 29 U.S.C. § 2601 (§ 2 of the Family and Medical Leave Act of 1993) · 29 U.S.C. § 2611 (§ 101 of the Family and Medical Leave Act of 1993) · 29 U.S.C. § 2612 (§ 102 of the Family and Medical Leave Act of 1993) · 29 U.S.C. § 2614 (§ 104 of the Family and Medical Leave Act of 1993) · 29 U.S.C. § 2615 (§ 105 of the Family and Medical Leave Act of 1993) · 29 U.S.C. § 2617 (§ 107 of the Family and Medical Leave Act of 1993) · 29 U.S.C. § 2654 (§ 404 of the Family and Medical Leave Act of 1993)
Relies on Anderson v. Liberty Lobby, Inc. · Monell v. Department of Social Services of City of New York · Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics · Kentucky v. Graham · Montana v. United States
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 124 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“First, Section 2611(4)(A) segregates the provision imposing individual liability from the public agency provision. Second, an interpretation that commingles the individual liability provision with the public agency provision renders certain provisions of the statute superfluous and results in several oddities. Finally, as evidenced by other provisions of the statute, the FMLA distinguishes its definition of employer from that provided in the FLSA by separating the individual liability and public agency provisions.”
6 later decisions quote this exact passage · from the majority“(4) Employer. (A) In general. The term “employer”— (i) means any person engaged in commerce or in any industry or activity affecting commerce who employs 50 or more employees for each working day during each of 20 or more calendar workweeks in the current or preceding calendar year; (ii) includes— (I) any person who acts, directly or indirectly, in the interest of an employer to any of the employees of such employer; and (II) any successor in interest of an employer; (iii) includes any “public agency”, as defined in section 3(x) of the Fair Labor Standards Act of 1938 (29 U.S.C. 203(x)); and (iv) includes the General Accounting Office [Government Accountability Office] and the Library of Congress.”
5 later decisions quote this exact passage · from the majority“... in the FMLA, Congress explicitly took “Public Agency” out of the private employer definition and disconnected it from liability based on a person acting directly or indirectly in the interest of an employer. Therefore, a better way to view the situation is that the FMLA corrected the ambiguity of the FLSA, as opposed to letting the ambiguity of the FLSA control the interpretation of the FMLA.”
3 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.