Case Citator › Michael Sato v. Orange Cty. Dept. of Education

Michael Sato v. Orange Cty. Dept. of Education

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

Questioned by some courts
Court
Ninth Circuit
Citation
861 F.3d 923
Decided
Confirmed treatments
1
Flagged citations read
31 of 31
Citing cases (total)
31
Treatment dates
2024
Questioned by some courts
At least one reviewed court has questioned this case’s reasoning or continued validity. No reviewed court has overruled it. Michael Sato v. Orange County Department of Education has been questioned: all 31 flagged citations have been read, with the confirmed treatment listed below. An unpublished Ninth Circuit disposition questioned whether its California school board immunity holding survives the court's later en banc decision in Kohn v. State Bar of California.
More on how this was screened

That disposition did not decide the issue; other courts have continued to apply Sato.

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.

31 later cases cite Michael Sato v. Orange Cty. Dept. of Education; 31 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 Sato v. Orange Cty. Dept. of Education?

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

Questioned

  • An unpublished Ninth Circuit disposition questioned whether Sato's conclusion that California school boards are arms of the state remains good law after an en banc change to the immunity framework.

    Riley's American Heritage Farms v. Elsasser · Ninth Circuit · filed

    It is not clear that Belanger’s and Sato’s conclusions about California school boards being arms of the state remain good law after Kohn v. State Bar of California, 87 F.4th 1021 (9th Cir. 2023) (en banc). We need not resolve that question.
    Read the full opinion on CourtListener →

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