Case Citator › Goodman v. Lukens Steel Co.

Goodman v. Lukens Steel Co.

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

Superseded by statute
Court
Third Circuit
Citation
777 F.2d 113
Decided
Confirmed treatments
2
Flagged citations read
79 of 79
Citing cases (total)
241
Treatment dates
1986–2004
Superseded by statute
A reviewed court treats this case as superseded by later legislation. Goodman v. Lukens Steel Co.'s borrowed state limitations period was superseded for § 1981 claims made possible by federal legislation enacted after 1990. In Jones v. R.R.
More on how this was screened

Donnelley & Sons Co., the Supreme Court applied the four-year federal period to those new claims while preserving Goodman's rule for earlier claims. Nazaire v. Trans World Airlines, Inc. separately declined to follow Goodman's limitations rule in the Seventh Circuit. All 79 flagged citations have been read; the two confirmed treatments are 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.

241 later cases cite Goodman v. Lukens Steel Co.; 79 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 Goodman v. Lukens Steel Co.?

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

Superseded by statute

  • The Supreme Court held that the federal four-year period enacted in 28 U.S.C. § 1658 governs § 1981 claims made possible by legislation after 1990, displacing Goodman's borrowed state period for those claims.

    Jones v. R.R. Donnelley & Sons Co. · Supreme Court of the United States · filed

    We held in Goodman v. Lukens Steel Co., 482 U. S. 656, 660 (1987), that federal courts should apply “the most appropriate or analogous state statute of limitations” to claims based on asserted violations of § 1981. ... We conclude that a cause of action “aris[es] under an Act of Congress enacted” after December 1,1990 — and therefore is governed by § 1658’s 4-year statute of limitations — if the plaintiff’s claim against the defendant was made possible by a post-1990 enactment.
    Read the full opinion on CourtListener →

Declined to follow

  • The Seventh Circuit declined to follow Goodman's limitations analysis and adopted the reasoning of Judge Garth's dissent.

    Nazaire v. Trans World Airlines, Inc. · Seventh Circuit · filed

    We decline to follow the Third Circuit and, instead, adopt the reasoning of Judge Garth’s dissenting opinion in Goodman.
    Read the full opinion on CourtListener →

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