Wright v. Heyne’s Empirical Analysis

Citation profile

10 federal appellate · 4 district · 1 state decisions

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.

1. “[T]he relevant knowledge required to trigger the statute of limitations under 29 U.S.C. § 1113 (2) is knowledge of the facts or transaction that constituted the alleged violation; it is not necessary that the plaintiff also have actual knowledge that the facts establish a cognizable legal claim under ERISA in order to trigger the running of the statute. This view is not only in accord with our previous ERISA “actual knowledge” decisions but it also furthers the policies underlying statutes of limitations. Among the basic policies served by statutes of limitations is preventing plaintiffs from sleeping on their rights and prohibiting the prosecution of stale claims.”

   6 later decisions quote this exact passage · from the majority
   e.g. Agi Consulting L. L.C. v. Am. Nat'l Ins. Co. · Neuma, Inc. v. Wells Fargo & Co.

2. “[t]he relevant knowledge for triggering the statute of limitations is knowledge of the facts or transaction that constituted the alleged violation. Consequently, it is not necessary for a potential plaintiff to have knowledge of every last detail of a transaction, or knowledge of its illegality.” Martin v. Consultants & Adm’rs, Inc., 966 F.2d 1078 , 1086 (7th Cir.1992) (emphasis in original); see Wright v. Heyne, 349 F.3d 321, 330 (6th Cir.2003) (”

   3 later decisions quote this exact passage · from the majority
   e.g. Agi Consulting L. L.C. v. Am. Nat'l Ins. Co. · Bernaola v. Checksmart Fin. LLC

3. “No action may be commenced under this subchapter with respect to a fiduciary’s breach of any responsibility, duty, or obligation under this part ... after the earlier of— (1) six years after (A) the date of the last action which constituted a part of the breach or violation, or (B) in the case of an omission the latest date on which the fiduciary could have cured the breach or violation, or (2) three years after the earliest date on which the plaintiff had actual knowledge of the breach or violation; except that in the case of fraud or concealment, such action may be commenced not later than six years after the date of discovery of such breach or violation.”

   2 later decisions quote this exact passage · from the majority
   e.g. Brown v. Owens Corning Investment Review Committee · 565 F. Supp. 2d 879 - Toledo Blade Newspaper Unions Blad Pension Plan v. Investment Performance Services, LLC