Henry G. Mack v. South Bay Beer Distributors, Inc., Dba Bay Beer Distributors, a California Corporation
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
The Supreme Court rejected Mack's rule that unreviewed state administrative findings preclude later federal litigation under the Age Discrimination in Employment Act. The other opinions generally repeated that history while continuing to rely on Mack's distinct rule allowing judicial notice of administrative records and other public materials.
693 later cases cite Henry G. Mack v. South Bay Beer Distributors, Inc., Dba Bay Beer Distributors, a California Corporation; 210 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
Abrogated
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The Supreme Court abrogated Mack's rule that unreviewed state administrative findings preclude later federal ADEA litigation, holding that those findings have no preclusive effect.
Astoria Federal Savings & Loan Ass'n v. Solimino · Supreme Court of the United States · filed
The question presented is whether claimants under the Age Discrimination in Employment Act of 1967 (Age Act or Act), 81 Stat. 602, as amended, 29 U. S. C. § 621 et seq., are collaterally estopped to relitigate in federal court the judicially unreviewed findings of a state administrative agency made with respect to an age-discrimination claim. We hold that such findings have no preclusive effect on federal proceedings. … We granted certiorari, 498 U. S. 1023 (1991), to resolve the conflict between the ruling here under review, see also Duggan v. Board of Education of East Chicago Heights, Dist. No. 169, Cook County, Ill., 818 F. 2d 1291 (CA7 1987), and those of the Eighth Circuit in Stillians, supra, and of the Ninth Circuit in Mack v. South Bay Beer Distributors, Inc., 798 F. 2d 1279 (1986).
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