Case Citator › Rockwell International Corp. v. United States

Rockwell International Corp. v. United States

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

Superseded by statute
Court
Supreme Court of the United States
Citation
549 U.S. 457
Decided
Confirmed treatments
2
Flagged citations read
44 of 44
Citing cases (total)
44
Treatment dates
2011–2025
Superseded by statute
A reviewed court treats this case as superseded by later legislation. Rockwell International Corp. v. United States remains useful for claims under the former False Claims Act text, but Congress superseded its jurisdictional reading of the public-disclosure bar. The Second Circuit identified that change in the 2010 amendment.
More on how this was screened

The Supreme Court later declined to follow Rockwell's footnote about jurisdiction after removal. Both treatments are listed below; all 44 flagged citations have been read.

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.

44 later cases cite Rockwell International Corp. v. United States; 44 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 Rockwell International Corp. v. United States?

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Superseded by statute

  • The Second Circuit stated that Congress's 2010 amendment superseded Rockwell's jurisdictional reading of the former False Claims Act public-disclosure bar.

    City of New York v. Mickalis Pawn Shop, LLC · Second Circuit · filed

    with Rockwell Int’l Corp. v. United States, 549 U.S. 457, 463, 467-68, 127 S.Ct. 1397, 167 L.Ed.2d 190 (2007) (determining that False Claims Act, former 31 U.S.C. § 3730(e)(4)(A), was jurisdictional insofar as it declared that “[n]o court shall have jurisdiction over an action under this section” unless a specified condition applies), superseded by statute, Patient Protection and Affordable Care Act, Pub.L. No. 111-148, § 10104(j)(2) (codified as amended at 31 U.S.C. § 3730(e)(4)(A)).
    Read the full opinion on CourtListener →

Limited

  • The Supreme Court declined to follow Rockwell's footnote suggesting that a removed case stays in federal court after an amended complaint drops its federal claims.

    Royal Canin U.S.A., Inc. v. Wullschleger · Supreme Court of the United States · filed

    But still, the footnote is dictum, and does not control the outcome here. Rockwell was an original federal case, not a removed one.
    Read the full opinion on CourtListener →

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