Case Citator › Bonnette v. California Health and Welfare Agency

Bonnette v. California Health and Welfare Agency

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

Declined by some courts
Court
Ninth Circuit
Citation
704 F.2d 1465
Decided
Confirmed treatments
1
Flagged citations read
54 of 54
Citing cases (total)
54
Treatment dates
1997
Declined by some courts
At least one reviewed court has declined to follow this case. No reviewed court has overruled it. Bonnette v. California Health and Welfare Agency was declined in the prison labor context by the Eleventh Circuit; its general Fair Labor Standards Act employer analysis continues to be applied. All 54 flagged citations have been read, and the 1 confirmed adverse treatment is listed below.
More on how this was screened

Most later opinions used Bonnette's four factors or its broader economic realities approach. Many citations also note that the Supreme Court later overruled the governmental immunity test Bonnette discussed, which does not undo Bonnette's employer holding. Villarreal v. Woodham appears in two opinion records for the same Eleventh Circuit decision and is listed once. The full Guifu Li v. A Perfect Day Franchise opinion was retrieved on a second attempt and read. Garcia v. San Antonio Metropolitan Transit Authority was read directly: it cites Bonnette as an example of a case denying state immunity while overruling National League of Cities, but does not expressly overrule Bonnette.

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.

54 later cases cite Bonnette v. California Health and Welfare Agency; 54 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 Bonnette v. California Health and Welfare Agency?

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

  • The Eleventh Circuit rejected use of Bonnette's four employer factors to decide whether a pretrial detainee working for a correctional facility was covered by the FLSA.

    Villarreal v. Woodham · Eleventh Circuit · filed

    We agree with this approach and adopt the reasoning articulated by the Seventh Circuit in Vanskike, 974 F.2d at 809-12, in rejecting the Bonnette four factor standard in the prison context.
    Read the full opinion on CourtListener →

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