Case Citator › Leibowitz v. Cornell University

Leibowitz v. Cornell University

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

Superseded by statute
Court
Second Circuit
Citation
584 F.3d 487
Decided
Confirmed treatments
1
Flagged citations read
37 of 37
Citing cases (total)
37
Treatment dates
2013

Status

Superseded by statute
A reviewed court treats this case as superseded by later legislation. Leibowitz v. Cornell University has been superseded by statute on its New York City Human Rights Law analysis: all 37 flagged citations have been read, and the confirmed treatment is listed below. Mihalik v. Credit Agricole Cheuvreux North America, Inc. held that the city's 2005 Restoration Act requires an analysis independent of federal and state discrimination standards, displacing Leibowitz's earlier statement that those standards were coextensive.
More on how this was screened

Later courts continue to apply Leibowitz's federal rule that refusing a sought contract renewal can be an adverse employment action; their references to statutory supersession report Mihalik's treatment.

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.

37 later cases cite Leibowitz v. Cornell University; 37 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.

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Treatments

Superseded by Statute

  • The Second Circuit held that the New York City Restoration Act requires an independent city-law discrimination analysis, displacing Leibowitz's statement that city claims follow the federal and state frameworks.

    Mihalik v. Credit Agricole Cheuvreux North America, Inc. · Second Circuit · filed

    For many years, we construed the NYCHRL to be coextensive with its federal and state counterparts. See, e.g., Estate of Hamilton v. City of New York, 627 F.3d 50, 55 (2d Cir. 2010); Leibowitz v. Cornell Univ., 584 F.3d 487, 498 n.1 (2d Cir. 2009); Cruz v. Coach Stores, Inc., 202 F.3d 560, 565 n.1 (2d Cir. 2000). In 2005, however, the New York City Council amended the NYCHRL by passing the Local Civil Rights Restoration Act of 2005 (the "Restoration Act"), N.Y.C. Local L. No. 85. ... As amended, the NYCHRL requires an independent analysis.
    Read the full opinion on CourtListener →

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