Lynn Armbruster v. Terry Quinn
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
Arbaugh v. Y & H Corp. held that Title VII's fifteen-employee minimum is an element of a claim rather than a limit on federal jurisdiction, rejecting Armbruster's contrary rule. The Sixth Circuit later said in Thomas v. Miller that Arbaugh expressly overruled Armbruster on that point. Earlier, a district court in Da Silva v. Kinsho International Corp. had declined to follow the same jurisdictional rule. Those two treatments are listed below. Later courts continued to apply Armbruster's separate single-employer analysis.
27 later cases cite Lynn Armbruster v. Terry Quinn; 27 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
Overruled in part
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The Supreme Court rejected Armbruster's rule that Title VII's fifteen-employee minimum limits federal subject-matter jurisdiction.
Arbaugh v. Y & H Corp. · Supreme Court of the United States · filed
conflicting opinions in Courts of Appeals on the question whether Title VII’s employee-numerosity requirement, 42 U. S. C. §2000e(b), is jurisdictional or simply an element of a plaintiff’s claim for relief. Compare, e.g., 380 F. 3d, at 223–225 (Title VII’s employee-numerosity requirement is jurisdictional), and Armbruster v. Quinn, 711 F. 2d 1332, 1335 (CA6 1983) (same) ... we hold that the threshold number of employees for application of Title VII is an element of a plaintiff’s claim for relief, not a jurisdictional issue.
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Declined to follow
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The district court declined Armbruster's jurisdictional treatment of Title VII's fifteen-employee minimum and treated the issue as part of the merits.
Da Silva v. Kinsho International Corp. · Southern District of New York · filed
Armbruster v. Quinn, 711 F.2d 1332, 1335(“[t]he essential question in this case is whether the plaintiffs’ are barred from bringing their claim in federal court by the Title VII jurisdictional requirement of fifteen employees”). ... Although the Second Circuit has yet directly to address the issue at bar, the decision in Nowak strongly suggests that one must conclude that the instant dismissal of the Plaintiffs Title VII claim is merits-based rather than jurisdictional. ... Similarly, in the case at bar, the inquiry (as to number of employees) necessary to assess Plaintiffs Title VII claim was so bound up in the merits of the claim that the Court’s determination (more) appropriately warrants dismissal under Fed. R.Civ.P. 12(b)(6) for failure to state a claim than under Fed.R.Civ.P. 12(b)(1) for lack of subject matter jurisdiction.
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