Smith v. ABS Industries, Inc.’s Empirical Analysis
890 F.2d 841 · 1989
Citation profile
20 federal appellate · 1 district · 1 state decisions
How this case has been cited
Cited by 38 later decisions — most recently December 2014 · most notably Wulf v. Quantum Chemical Corp. (1994), International Union, United Automobile, Aerospace & Agricultural Implement Workers v. BVR Liquidating, Inc. (1999)
20 federal appellate · 1 district · 1 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. § 1132 (§ 502 of the Employee Retirement Income Security Act of 1974) · 29 U.S.C. § 185 (§ 301 of the Labor Management Relations Act of 1947 (Taft-Hartley Act))
Relies on United Steelworkers v. American Manufacturing Co. · Carstea v. Poplar Tree Homeowners Ass'n · United States v. Monton · In re Disbarment of Cooper · International Union United Automobile Aerospace and Agricultural Implement Workers of America Uaw v. Yard-Man Incorporated
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 38 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“retiree benefits are in a sense “status” benefits which, as such, carry with them an inference that they continue so long as the prerequisite status is maintained. Thus, when the parties contract for benefits which accrue upon achievement of retiree status, there is an inference that the parties likely intended those benefits to continue as long as the beneficiary remains a retiree. This is not to say that retiree insurance benefits are necessarily interminable by their nature. Nor does any federal labor policy identified to this Court presumptively favor the finding of interminable rights to retiree insurance benefits when the collective bargaining agreement is silent. Rather, as part of the context from which the collective bargaining agreement arose, the nature of such benefits simply provides another inference of intent. Standing alone, this factor would be insufficient to find an intent to create interminable benefits.”
3 later decisions quote this exact passage · from the concurrence“[B]oth parties have offered plausible interpretations of the agreement drawn from the contractual language itself [which] demonstrates that the provision is ambiguous.”
2 later decisions quote this exact passage · from the concurrence“[T]he court should interpret each provision in question as part of the integrated whole. If possible each provision should be construed consistently with the entire document and the relative positions and purposes of the parties.”
1 later decision quote this exact passage · from the concurrence
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.