National Elevator Industry, Inc. v. Calhoon’s Empirical Analysis
957 F.2d 1555 · 1992
Citation profile
30 federal appellate · 8 district · 5 state decisions
Relationships
Relies on Shaw v. Delta Air Lines, Inc. · Ingersoll-Rand Co. v. McClendon · Metropolitan Life Insurance v. Massachusetts · Fort Halifax Packing Co. v. Coyne · Fmc Corporation v. Holliday
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 53 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“First, laws that regulate the type of benefits or terms of ERISA plans. Second, laws that create reporting, disclosure, funding, or vesting requirements for ERISA plans. Third, laws that provide rules for the calculation of the amount of benefits to be paid under ERISA plans. Fourth, laws and common-law rules that provide remedies for misconduct growing out of the administration of the ERISA plan.”
10 later decisions quote this exact passage · from the majority“[I]t is clear that the state law claims here do not relate to an ERISA plan. The state laws involved do not regulate the type of benefits or terms of the plan; they do not create reporting, disclosure, funding or vesting requirements for the plan; they do not affect the calculation of benefits; and they are not common law rules designed to rectify faulty plan administration .... [S]tate laws of negligence, indemnity, and fraud are “laws of general application — not specifically targeting ERISA plans — that involve traditional areas of state regulation and do not affect ‘relations among the principal ERISA entities.’ ””
4 later decisions quote this exact passage · from the majority“A law 'relates to' an employee benefit plan, in the normal sense of the phrase, if it has a connection with or reference to such a plan.”
4 later decisions 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.