Case Citator › Anthony F. McDonald v. Frank A. Hall

Anthony F. McDonald v. Frank A. Hall

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

Declined by some courts
Court
First Circuit
Citation
610 F.2d 16
Decided
Confirmed treatments
1
Flagged citations read
78 of 78
Citing cases (total)
1,175
Treatment dates
1989

Status

Declined by some courts
At least one reviewed court has declined to follow this case. No reviewed court has overruled it. Anthony F. McDonald v. Frank A. Hall has been fully reviewed: all 78 flagged citations have been read, with the 1 confirmed treatment listed below. Adams v. Wainwright declined to adopt McDonald's heightened “but for” causation burden for prisoner-retaliation claims in the Eleventh Circuit.
More on how this was screened

The other reviewed opinions continued to apply McDonald's retaliation and liberal-construction rules or placed unrelated treatment language near the citation, most often history concerning McGore v. Wrigglesworth and Jones v. Bock.

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.

1,175 later cases cite Anthony F. McDonald v. Frank A. Hall; 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.

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Treatments

Declined to follow

  • The Eleventh Circuit expressly declined to adopt McDonald's “but for” causation standard for prisoner-retaliation claims because it placed a greater burden of proof on prisoners.

    Adams v. Wainwright · Eleventh Circuit · filed

    The state urges us to adopt the “but for” standard set forth in McDonald v. Hall, 610 F.2d 16, 18-19 (1st Cir.1979) (prisoner must prove that he or she would not have been transferred “but for” an assertion of constitutional rights). We decline to adopt the “but for” standard. See Hall v. Evans, 86-8782 (11th Cir. March 9, 1988) [842 F.2d 337 (table)] (“To the extent that the ‘but for’ test places a greater burden of proof on the appellant, we decline to follow it.”).
    Read the full opinion on CourtListener →

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