Case Citator › Michael Meyers, Individually and as Representative of a Class v. Pennypack Woods Home Ownership Association and Marion A. Steinbronn

Michael Meyers, Individually and as Representative of a Class v. Pennypack Woods Home Ownership Association and Marion A. Steinbronn

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

Abrogated
Court
Third Circuit
Citation
559 F.2d 894
Decided
Confirmed treatments
2
Flagged citations read
78 of 78
Citing cases (total)
412
Treatment dates
1985–2000
Abrogated
A reviewed court treats this case as abrogated by later authority. Meyers v. Pennypack Woods Home Ownership Association has been abrogated in part and limited: all 78 flagged citations have been read, with the 2 confirmed treatments listed below. The Third Circuit held that intervening Supreme Court authority displaced Meyers's limitations rule, and the Seventh Circuit declined to extend Meyers's housing-tester standing rationale to employment testers who lacked genuine contractual intent.
More on how this was screened

The other reviewed opinions applied Meyers's surviving discovery-sanction and witness-exclusion factors, reported Goodman v. Lukens Steel Co. as subsequent history, or used nearby adverse language for unrelated rulings. CourtListener lists Kyles v. J.K. Guardian Security Services, Inc. more than once; it produced one treatment entry.

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.

412 later cases cite Michael Meyers, Individually and as Representative of a Class v. Pennypack Woods Home Ownership Association and Marion A. Steinbronn; 78 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 Michael Meyers, Individually and as Representative of a Class v. Pennypack Woods Home Ownership Association and Marion A. Steinbronn?

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

Abrogated

  • The Third Circuit held that intervening Supreme Court authority displaced Meyers's six-year limitations approach and required section 1981 actions to use the forum state's personal-injury limitations period.

    Goodman v. Lukens Steel Co. · Third Circuit · filed

    As we noted earlier, the reasoning employed by the Supreme Court in Wilson is inconsistent with the Polite approach as used in Davis and Pennypack Woods. This court has consistently held that one panel may not overrule an earlier panel’s decision. See Third Circuit Internal Operating Procedure VIII C. However, we have recognized that this principle must yield when a panel opinion is in conflict with an intervening Supreme Court precedent. “Where, however, a holding of this Court is overruled or rejected by the Supreme Court, IOP 8c does not require in banc consideration to align this court's jurisprudence with Supreme Court teaching.” Rubin v. Buckman, 727 F.2d 71, 74 (3d Cir.1984) (Garth, J. concurring). See also West v. Keve, 721 F.2d 91, 93 (3d Cir.1983); Geraghty v. United States Parole Commission, 719 F.2d 1199, 1209 (3d Cir.1983). The rationale used in Davis cannot co-exist with Wilson, and accordingly does not bind us here. We hold, therefore, that the personal injury statute of limitations of the forum state supplies the most analogous statute of limitations for actions brought under § 1981.
    Read the full opinion on CourtListener →

Limited

  • The Seventh Circuit declined to extend Meyers's housing-tester standing rationale to section 1981 employment testers who had no genuine intent to enter an employment contract.

    Kyles v. J.K. Guardian Security Services, Inc. · Seventh Circuit · filed

    The Third Circuit in Meyers, 559 F.2d at 898, and the Eleventh Circuit in Watts, 758 F.2d at 1485, both relied heavily on Evers and Pierson in concluding that testers have standing to bring suit under section 1982. These two cases cannot bear the full weight of the plaintiffs’ burden on standing, however.
    Read the full opinion on CourtListener →

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