Anthony F. McDonald v. Frank A. Hall
Is it still good law? What later courts have actually done to this case.
Status
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.
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.
Relying on Anthony F. McDonald v. Frank A. Hall?
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
Declined to follow
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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.”).
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