Case Citator › Martin John Beattie v. United States

Martin John Beattie v. United States

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

Overruled in part
Court
D.C. Circuit
Citation
756 F.2d 91
Decided
Confirmed treatments
1
Flagged citations read
36 of 36
Citing cases (total)
36
Treatment dates
1993
Overruled in part
A reviewed court has overruled part of this case’s holding. Martin John Beattie v. United States was overruled in part on whether the Federal Tort Claims Act covers torts in Antarctica. The Supreme Court held in Smith v. United States that the Act excludes such claims, contrary to Beattie's holding.
More on how this was screened

Courts continue to cite Beattie's separate venue analysis. All 36 flagged citations have been read; the confirmed treatment is listed below.

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.

36 later cases cite Martin John Beattie v. United States; 36 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

  • The Supreme Court held that Antarctica falls within the FTCA's foreign country exception, displacing Beattie's contrary holding while leaving its separate venue analysis intact.

    Smith v. United States · Supreme Court of the United States · filed

    But the ordinary meaning of the language itself, we think, includes Antarctica, even though it has no recognized government. ... Cf. Beattie v. United States; 244 U. S. App. D. C. 70, 756 F. 2d 91 (1984) (holding that Antarctica is not a “foreign country” within the meaning of the FTCA).
    Read the full opinion on CourtListener →

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