Sears v. Chrysler Corp.’s Empirical Analysis
1995
Citation profile
1 district ·
How this case has been cited
Cited by 3 later decisions — most recently August 2015
1 district ·
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. § 1002 (§ 3 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 Firestone Tire and Rubber Company v. Bruch · Franchise Tax Board of the State of California v. Construction Laborers Vacation Trust for Southern California · Shaw v. Delta Air Lines, Inc. · Pilot Life Insurance v. Dedeaux · Caterpillar Inc. v. Williams
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 3 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[.Metropolitan Life ] ruled that the exception [to the well-pleaded complaint rule] is narrowly limited in the ERISA context to state common law or statutory claims that fall within the ERISA civil enforcement provision of 29 U.S.C. § 1132 (a)(1)(B) because “the legislative history consistently sets out this clear intention to make [ § 1132(a)(1)(B)] suits brought by participants or beneficiaries federal questions for the purpose of federal court jurisdic-tion____” Id. at 66. Therefore, in order to ■come within the exception a court must conclude that the common law or statutory claim under state law should be characterized as a superseding ERISA action “to recover benefits due to him under the terms of his plan, to enforce his rights under the terms of -the plan, or to clarify his rights to future benefits under the terms of the plan,” as provided in 1132(a)(1)(B). The Court specifically stated “ERISA pre-emption, without more, does not convert a state claim into an action arising under federal law.” Metropolitan Life, at 64. Section 1144 falls precisely into this category. It allows ERISA to preempt state laws when they “relate to” matters governed by ERISA but does not create a federal cause of action for matters which only “relate to” ERISA’s field of concern. Thus, § 1144 preemption does not create a federal cause of action itself, and cannot convert a state cause of action into a federal cause of action under the well-pleaded complaint rule. As a consequence, no removal”
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.