Case Citator › Jane M. Wooldridge v. Marlene Industries Corporation and Russell Sportswear Corporation

Jane M. Wooldridge v. Marlene Industries Corporation and Russell Sportswear Corporation

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

Overruled in part
Court
Sixth Circuit
Citation
898 F.2d 1169
Decided
Confirmed treatments
1
Flagged citations read
36 of 36
Citing cases (total)
36
Treatment dates
2001
Overruled in part
A reviewed court has overruled part of this case’s holding. Jane M. Wooldridge v. Marlene Industries Corporation and Russell Sportswear Corporation was overruled in part on who qualifies as a prevailing party for an attorney fee award. The Supreme Court's decision in Buckhannon Board & Care Home, Inc. v. West Virginia Department of Health and Human Resources displaced Wooldridge's rule allowing fees when a lawsuit merely prompts a voluntary change in the defendant's conduct.
More on how this was screened

DiLaura v. Township of Ann Arbor later recognized that Buckhannon abrogated Wooldridge's prevailing party analysis. Wooldridge's separate fee calculation standards remain in use. 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 Jane M. Wooldridge v. Marlene Industries Corporation and Russell Sportswear Corporation; 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.

Relying on Jane M. Wooldridge v. Marlene Industries Corporation and Russell Sportswear Corporation?

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

Overruled in part

  • The Supreme Court held that a voluntary change in the defendant's conduct does not by itself make a plaintiff a prevailing party, displacing Wooldridge's contrary fee entitlement rule.

    Buckhannon Board & Care Home, Inc. v. West Virginia Department of Health and Human Resources · Supreme Court of the United States · filed

    We think, however, the “catalyst theory” falls on the other side of the line from these examples. It allows an award where there is no judicially sanctioned change in the legal relationship of the parties.
    Read the full opinion on CourtListener →

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