89 Conn. App. 821 - Chayoon v. Sherlock’s Empirical Analysis
2005
Citation profile
11 state decisions
Relationships
Applies 29 U.S.C. § 2601 (§ 2 of the Family and Medical Leave Act of 1993)
Relies on Ex Parte: Edward T Young · Puyallup Tribe, Inc. v. Department of Game of Washington · C & L Enterprises Inc. v. Citizen Band Potawatomi Indian Tribe of Oklahoma · Kizis v. Morse Diesel International, Inc. · Tierney v. Department of Human Services
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 13 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““In the tribal immunity context, a claim for damages against a tribal official lies outside the scope of tribal immunity only where the complaint pleads—and it is shown—that a tribal official acted beyond the scope of his authority to act on behalf of the [t]ribe.””
2 later decisions quote this exact passage“[A]s a matter of federal law, an Indian tribe is subject to suit only where Congress has authorized the suit or the tribe has waived its immunity ... and the tribe itself has consented to suit in a specific forum.... Absent a clear and unequivocal waiver by the tribe or congressional abrogation, the doctrine of sovereign immunity bars suits for damages against a tribe.... Although tribal immunity does not extend to individual members of a tribe ... [t]he doctrine of tribal immunity ... extends to individual tribal officials acting in their representative capacity and within the scope of their authority.... The doctrine does not extend to tribal officials when acting outside their authority in violation of state law.... Tribal immunity also extends to all tribal employees acting within their representative capacity and within the scope of their official authority.”
1 later decision quote this exact passage“It is insufficient for the plaintiff merely to allege that the defendants violated ... law or tribal policy in order to state a claim that they acted beyond the scope of their authority.... Such an interpretation would eliminate tribal immunity from damages actions because a plaintiff must always allege a wrong or a violation of law in order to state a claim for relief. In order to circumvent tribal immunity, the plaintiff must have alleged and proven, apart from whether the defendants acted in violation of federal law, that the defendants acted without any colorable claim of authority ....”
1 later decision quote this exact passage
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.