Goodman v. Lukens Steel Co.
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
Donnelley & Sons Co. held that 28 U.S.C. § 1658's four-year period governs claims made possible by the 1991 amendment to 42 U.S.C. § 1981, displacing Goodman's state-law borrowing rule for those claims while leaving it applicable to claims available under pre-1990 law. Smith v. Firestone Tire & Rubber Co., its Seventh Circuit affirmance, and Malhotra v. Cotter & Co. also held Goodman nonretroactive where litigants had relied on clear Seventh Circuit precedent. The remaining opinions applied Goodman's unaffected rules or reported these treatments and Goodman's own treatment of older Third Circuit precedent.
786 later cases cite Goodman v. Lukens Steel Co.; 88 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. 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 Goodman v. Lukens Steel 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
Superseded by Statute
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The Supreme Court held that 28 U.S.C. § 1658's four-year limitations period, rather than Goodman's state-law borrowing rule, governs claims made possible by post-1990 amendments to federal law.
Jones v. R.R. Donnelley & Sons Co. · Supreme Court of the United States · filed
We held in Goodman v. Lukens Steel Co., 482 U. S. 656, 660 (1987), that federal courts should apply “the most appropriate or analogous state statute of limitations” to claims based on asserted violations of § 1981. Three years after our decision in Goodman, Congress enacted a catchall 4-year statute of limitations for actions arising under federal statutes enacted after December 1, 1990. 28 U. S. C. § 1658. ... Because petitioners’ hostile work environment, wrongful termination, and failure to transfer claims did not allege a violation of the pre-1990 version of § 1981 but did allege violations of the amended statute, those claims “ar[ose] under” the amendment to § 1981 contained in the 1991 Act.
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Limited
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The district court held Goodman's personal-injury limitations rule nonretroactive because it displaced clear Seventh Circuit precedent on which the plaintiff had relied.
Smith v. Firestone Tire & Rubber Co. · C.D. Ill. · filed
For the following reasons, this Court declines to apply Goodman retroactively to the case at bar.
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The district court held Goodman nonretroactive and retained the earlier five-year limitations period because Goodman had displaced clear Seventh Circuit precedent.
Malhotra v. Cotter & Co. · N.D. Ill. · filed
This court concludes that, because Goodman overruled clear Seventh Circuit precedent, see Waters v. Wisconsin Steel Works, 427 F.2d 476 (7th Cir.), cert. denied 400 U.S. 911, 91 S.Ct. 137, 27 L.Ed.2d 161 (1970), it should not be given retroactive effect in this case.
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The Seventh Circuit affirmed that Goodman was nonretroactive where the plaintiff had relied on the circuit's settled five-year limitations period.
Leroy Smith, Jr. v. Firestone Tire and Rubber Company · Seventh Circuit · filed
This case is therefore distinguishable from Goodman in which the Court determined that there was no clear precedent within the Third Circuit on which plaintiffs could have relied in filing their suit and applied the statute of limitations retroactively to the claims of that class of plaintiffs. Plaintiff here, however, was clearly justified in relying on this Court’s case law applying the five-year statute of limitations prior to Goodman.
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