Valentine v. Standard & Poor's’s Empirical Analysis
1999
Citation profile
3 federal appellate · 5 district · 2 state decisions
How this case has been cited
Cited by 64 later decisions — most recently April 2018 · most notably Sista v. CDC Ixis North America, Inc. (2006), Robertson v. Mylan Laboratories, Inc. (2004)
3 federal appellate · 5 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
Applies 29 U.S.C. § 701 (Employment Opportunities for Individuals With Disabilities Act) · 29 U.S.C. § 794 · 42 U.S.C. § 12101 (§ 2 of the Americans with Disabilities Act of 1990) · 42 U.S.C. § 12111 (§ 101 of the Americans with Disabilities Act of 1990) · 42 U.S.C. § 12112 (§ 102 of the Americans with Disabilities Act of 1990) · 42 U.S.C. § 12113 (§ 103 of the Americans with Disabilities Act of 1990) · 42 U.S.C. § 12117 (§ 107 of the Americans with Disabilities Act of 1990) · 42 U.S.C. § 12203 (§ 503 of the Americans with Disabilities Act of 1990)
Relies on Anderson v. Liberty Lobby, Inc. · Celotex Corporation v. Catrett H · McDonnell Douglas Corp. v. Green · Texas Department of Community Affairs v. Burdine · Haines v. Kerner
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 64 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“the burden shifts to the employer to articulate some legitimate, nondiscriminatory reason for the employee’s discharge [or other adverse employment action]. At this stage, the employer need only articulate — but need not prove — the existence of a nondiscriminatory reason for its decision. If the defendant carries this burden of production, the presumption raised by the prima facie case is rebutted, and the factual inquiry proceeds to a new level of specificity. Once defendant meets its burden of production, the burden shifts back to plaintiff. Under the third tier of the McDonnell Douglas test, plaintiff bears the ultimate burden of proving that the reason proffered by the employer is a pretext for unlawful discrimination. In order to survive a motion for summary judgment, plaintiff must establish a genuine issue of material fact as to whether the employer’s reason ... is false and as to whether it is more likely that a discriminatory reason motivated the employer to make the adverse employment decision.”
7 later decisions quote this exact passage · from the majority“[a] plaintiff sustains an adverse employment action if he or she endures a materially adverse change in the terms and conditions of employment. To be materially adverse a change in working conditions must be more disruptive than a mere inconvenience or an alteration of job responsibilities. A materially adverse change might be indicated by a termination of employment, a demotion evidenced by a decrease in wage or salary, a less distinguished title, a material loss of benefits, significantly diminished material responsibilities, or other indices unique to a particular situation.”
1 later decision quote this exact passage · from the majority“a significant risk to the health or safety of others that cannot be eliminated by reasonable accommodation,”
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.