Case Citator › Sparrow v. United Air Lines, Inc.

Sparrow v. United Air Lines, Inc.

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

Overruled in part
Court
D.C. Circuit
Citation
216 F.3d 1111
Decided
Confirmed treatments
4
Flagged citations read
39 of 39
Citing cases (total)
39
Treatment dates
2002–2024
Overruled in part
A reviewed court has overruled part of this case’s holding. The D.C. Circuit held that Sparrow's former pleading standard for the causation element of Title VII retaliation claims is no longer binding after Twombly and Iqbal.
More on how this was screened

All 39 flagged citations have been read. The 4 confirmed treatments are listed below; the later ruling addresses that pleading standard, not every holding in Sparrow.

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.

39 later cases cite Sparrow v. United Air Lines, Inc.; 39 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 Sparrow v. United Air Lines, Inc.?

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 D.C. Circuit held that the lenient causation pleading standard drawn from Sparrow and Rochon is no longer binding for Title VII retaliation claims.

    Ho v. Garland · D.C. Circuit · filed

    Prior to Twombly and Iqbal, this Court had articulated a more liberal pleading standard for the causation element of Title VII retaliation claims, under which “in order to survive a motion to dismiss, all the complaint has to say, is ‘the [defendant] retaliated against me because I engaged in protected activity.’” Rochon v. Gonzales, 438 F.3d 1211, 1220 (D.C. Cir. 2006) (cleaned up); see also Sparrow v. United Air Lines Inc., 216 F.3d 1111, 1115 (D.C. Cir. 2000). This standard was based on Conley v. Gibson, 335 U.S. 41 (1957), which the Supreme Court abrogated in Twombly and Iqbal, see 550 U.S. at 560–63; 556 U.S. at 670. Thus, like a “chorus” of district judges in this Circuit, we hold that this pleading standard from Rochon and Sparrow “is no longer binding authority.”
    Read the full opinion on CourtListener →

Limited

  • The court declined to extend Sparrow's relaxed approach to a civil forfeiture claimant who failed to meet filing and verification requirements despite extensions and instructions.

    United States v. Funds from Prudential Securities · D.D.C. · filed

    However, to relax procedural requirements to the point that this court would allow the claimant’s claim to be filed would be an abhorration of the legal precedent in this area and would stretch the boundaries of relaxed procedural requirements beyond what the D.C. Circuit contemplated in Sparrow.
    Read the full opinion on CourtListener →

  • The court required factual context beyond Sparrow's minimal employment discrimination pleading example where the claim depended on unsupported assumptions about hiring practices.

    Greer v. Board of Trustees of the University of the District of Columbia · D.D.C. · filed

    To the extent that an employment discrimination claimant may survive a motion to dismiss by alleging “I was turned down for a job because of my race [or age or gender or prior protected activity],” Sparrow v. United Air Lines, Inc., 216 F.3d 1111, 1115 (D.C. Cir. 2000), Plaintiff only does so if the court makes multiple assumptions about the nature of the relevant hiring practices. Twombly and Iqbal require more factual context.
    Read the full opinion on CourtListener →

Questioned

  • The court said its dismissal of a discrimination counterclaim might conflict with Sparrow and observed that Sparrow relied on a pleading rule later abrogated by Twombly and Iqbal.

    Presidential Bank, FSB v. 1733 27th Street SE LLC · D.D.C. · filed

    Although the Court notes that its decision may appear in tension with the D.C. Circuit’s holding in the employment discrimination context that “all a complainant ha[d] to say to survive a motion to dismiss under Rule 12(b)(6)” was something to the effect of “I was turned down for a job because of my [protected status].” Sparrow v. United Air Lines, Inc., 216 F.3d 1111, 1115 (D.C. Cir. 2000). The D.C. Circuit’s holding in Sparrow drew from Conley v. Gibson, 355 U.S. 41, 45–46 (1957), which the Supreme Court has since abrogated in Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) and Ashcroft v. Iqbal, 556 U.S. 662 (2009).
    Read the full opinion on CourtListener →

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