Leibowitz v. Cornell University
Is it still good law? What later courts have actually done to this case.
Status
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.
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.
Relying on Leibowitz v. Cornell University?
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Superseded by Statute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 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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