Fitzgerald v. Codex Corp.’s Empirical Analysis
882 F.2d 586 · 1989
Citation profile
18 federal appellate · 27 district · 3 state decisions
How this case has been cited
Cited by 60 later decisions (2 by the Supreme Court) — most recently March 2018 · most notably Ingersoll-Rand Co. v. McClendon (1990), Renne v. Geary (1991)
18 federal appellate · 27 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.
Relationships
Applies 28 U.S.C. § 1331 · 28 U.S.C. § 1441 · 29 U.S.C. § 1001 (§ 2 of the Employee Retirement Income Security Act of 1974) · 29 U.S.C. § 1132 (§ 502 of the Employee Retirement Income Security Act of 1974) · 29 U.S.C. § 1140 (§ 510 of the Employee Retirement Income Security Act of 1974) · 29 U.S.C. § 1144 (§ 514 of the Employee Retirement Income Security Act of 1974)
Relies on Franchise Tax Board of the State of California v. Construction Laborers Vacation Trust for Southern California · Singleton v. Wulff · Shaw v. Delta Air Lines, Inc. · Pilot Life Insurance v. Dedeaux · Metropolitan Life Insurance v. Taylor
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 60 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“protect ... participants in employee benefit plans and their beneficiaries, by requiring the disclosure and reporting to participants and beneficiaries of financial and other information with respect thereto, by establishing standards of conduct, responsibility, and obligation for fiduciaries of employee benefit plans, and by providing for appropriate remedies, sanctions, and ready access to the Federal courts.”
2 later decisions quote this exact passage · from the majority“It shall be unlawful for any person to discharge, fine, suspend, expel, discipline, or discriminate against a participant or beneficiary for exercising any right to which he is entitled under the provisions of an employee benefit plan, ..., or for the purpose of interfering with the attainment of any right to which such participant may become entitled under the plan____”
2 later decisions quote this exact passage · from the majority“Fitzgerald’s complaint is grounded upon Codex’s alleged wrongful motivation in terminating his employment: to avoid payment under an ERISA plan to Fitzgerald’s former wife. This claim has much more than the requisite ‘connection or reference’ to an ERISA plan. Shaw v. Delta Airlines [sic], 463 U.S. 85, 97 , 103 S.Ct. 2890, 2900 , 77 L.Ed.2d 490 (1983). Its focus is Codex’s interference with alleged benefit rights. This is precisely the type of action that section 510 sought to cover and that is essential to the Act’s protection.”
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.