Case Citator › Hazel-Atlas Glass Co. v. Hartford-Empire Co.

Hazel-Atlas Glass Co. v. Hartford-Empire Co.

Is it still good law? What later courts have actually done to this case.

Overruled in part
Court
Supreme Court of the United States
Citation
322 U.S. 238
Decided
Confirmed treatments
4
Flagged citations read
92 of 99
Citing cases (total)
1,010
Treatment dates
1946–2013
Overruled in part
A reviewed court has overruled part of this case’s holding. Hazel-Atlas Glass Co. v. Hartford-Empire Co. remains overruled in part: of the 99 flagged citations, 92 citing opinions were read and the text of the other 7 could not be retrieved; the four confirmed treatments are listed below. Standard Oil overruled Hazel-Atlas's appellate-leave procedure but left its fraud-on-the-court doctrine intact.
More on how this was screened

Josserand, Washington, and Baker confined that doctrine in distinct contexts. The other reviewed opinions applied Hazel-Atlas's inherent-power and fraud-on-the-court rules, reported Standard Oil's partial overruling, or used nearby adverse language for another authority or ruling.

The treatments below are confirmed; unread citations could still change the overall status.
Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case, except the ones whose text could not be retrieved.

1,010 later cases cite Hazel-Atlas Glass Co. v. Hartford-Empire Co.; 99 of those citations sat close to treatment language and were flagged for reading; 92 of them have been read, and the text of 7 citing opinions could not be retrieved, so those remain unread. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Hazel-Atlas Glass Co. v. Hartford-Empire Co.?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Overruled in part

  • The Supreme Court overruled Hazel-Atlas's approval of a requirement that litigants obtain appellate leave before asking a district court to reopen a judgment under Rule 60(b).

    Standard Oil Co. of California v. United States · Supreme Court of the United States · filed

    The appellate-leave requirement adds to the delay and expense of litigation and also burdens the increasingly scarce time of the federal appellate courts. We see no reason to continue the existence of this “unnecessary and undesirable clog on the proceedings,” ... This Court held that appellate leave was required in In re Potts, 166 U. S. 263 (1897), and spoke approvingly of the practice in Hazel-Atlas Co. v. Hartford Co., 322 U. S. 238, 248 (1944).
    Read the full opinion on CourtListener →

Limited

  • The court confined Hazel-Atlas to extrinsic or collateral fraud and rejected extending it to authorize setting aside a final judgment for intrinsic fraud.

    Josserand v. Taylor · Court of Customs and Patent Appeals · filed

    We are unable to concur in the views expressed by counsel for appellee that it Avas the intention of the Supreme Court in the Hazel-Atlas Go. case, supra, to overrule the decisions of that court and those of the Circuit Courts of Appeals, hereinbefore cited, and to hold that a judgment or decree rendered by a federal court at a former term, obtained by intrinsic fraud as distinguished from extrinsic or collateral fraud, should be nullified in a proceeding such as here involved.
    Read the full opinion on CourtListener →

  • The Third Circuit confined Hazel-Atlas's inherent fraud-on-the-court power to civil judgments and held that governing statutes and criminal rules displaced any corresponding power to modify a criminal sentence.

    United States v. Washington · Third Circuit · filed

    However, both Hazel-Atlas and Chambers are civil cases. In the criminal context, the Supreme Court has held that district courts lack inherent supervisory power to enter an untimely judgment of acquittal sua sponte when doing so is in clear contradiction of Federal Rule of Criminal Procedure 29(c).
    Read the full opinion on CourtListener →

  • The Tenth Circuit held that invoking Hazel-Atlas and Rule 60(d)(3) does not exempt a fraud-on-the-court challenge to a criminal conviction from the second-or-successive habeas certification requirements.

    United States v. Baker · Tenth Circuit · filed

    Baker cites no authority and offers no reasoned basis for this court to conclude that an identical claim seeking the same relief, but invoking the district court’s inherent power under Rule 60(d)(3) and Hazel-Atlas, is exempt from the certification requirements in § 2255(h).
    Read the full opinion on CourtListener →

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