Case Citator › Zane Brent Edgington v. Missouri Department of Corrections

Zane Brent Edgington v. Missouri Department of Corrections

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

Abrogated
Court
Eighth Circuit
Citation
52 F.3d 777
Decided
Confirmed treatments
1
Flagged citations read
89 of 92
Citing cases (total)
188
Treatment dates
2005
Abrogated
A reviewed court treats this case as abrogated by later authority. Zane Brent Edgington v. Missouri Department of Corrections is abrogated in part: 89 of the 92 flagged citations were read, the text of the other 3 could not be retrieved, and the one confirmed treatment is listed below. Doe v. Cassel eliminated Edgington's common-law heightened-pleading requirement for Section 1983 suits against individual officials.
More on how this was screened

The other readable opinions reported that treatment in history parentheticals while continuing to apply Edgington's unaffected appointment-of-counsel standard. CourtListener lists the treating opinion twice, so both copies were reviewed, but the treatment is listed once, under the copy carrying the published citation.

The treatments below are confirmed; unread citations could still change the overall status.
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, except the ones whose text could not be retrieved.

188 later cases cite Zane Brent Edgington v. Missouri Department of Corrections; 92 of those citations sat close to treatment language and were flagged for reading; 89 of them have been read, and the text of 3 citing opinions could not be retrieved, so those remain unread. 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 Zane Brent Edgington v. Missouri Department of Corrections?

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Treatments

Abrogated

  • The Eighth Circuit abrogated Edgington's common-law heightened-pleading requirement for Section 1983 suits against individual defendants, holding that heightened pleading may be imposed only by the Federal Rules or a federal statute.

    Doe v. Cassel · Eighth Circuit · filed

    We now recognize Edgington’s heightened pleading requirement in § 1983 suits against individual defendants has been abrogated. The only permissible heightened pleading requirements in civil suits are those contained in the Federal Rules of Civil Procedure or those in federal statutes enacted by Congress.
    Read the full opinion on CourtListener →

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