Case Citator › Metcalf & Eddy, Inc. v. Puerto Rico Aqueduct and Sewer Authority

Metcalf & Eddy, Inc. v. Puerto Rico Aqueduct and Sewer Authority

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

Limited by some courts
Court
First Circuit
Citation
991 F.2d 935
Decided
Confirmed treatments
1
Flagged citations read
36 of 36
Citing cases (total)
36
Treatment dates
2003

Status

Limited by some courts
At least one reviewed court has limited this case’s holding to narrower facts or a narrower rule. No reviewed court has overruled it. Metcalf & Eddy, Inc. v. Puerto Rico Aqueduct and Sewer Authority remains authoritative on Puerto Rico's aqueduct authority, but the First Circuit refined its test for deciding when a public entity shares sovereign immunity. All 36 flagged citations have been read.
More on how this was screened

The confirmed change to the test is listed below; the later court said Metcalf & Eddy's rule about risk to the public treasury remains valid.

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 Metcalf & Eddy, Inc. v. Puerto Rico Aqueduct and Sewer Authority; 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 Metcalf & Eddy, Inc. v. Puerto Rico Aqueduct and Sewer Authority?

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

Limited

  • The First Circuit refined Metcalf & Eddy's arm-of-state test into an inquiry that first examines whether the state structured the entity to share its sovereignty, then makes risk to the public treasury decisive if the structural factors conflict.

    Fresenius Medical Care Cardiovascular Resources, Inc. v. Puerto Rico & the Caribbean Cardiovascular Center Corp. · First Circuit · filed

    we think the Hess analysis governs and has refined the Metcalf & Eddy analysis
    Read the full opinion on CourtListener →

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