Case Citator › W.B. v. Matula

W.B. v. Matula

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

Overruled in part
Court
Third Circuit
Citation
67 F.3d 484
Decided
Confirmed treatments
2
Flagged citations read
71 of 71
Citing cases (total)
71
Treatment dates
2000–2007
Overruled in part
A reviewed court has overruled part of this case’s holding. W.B. v. Matula's rule allowing a Section 1983 claim for violations of the Individuals with Disabilities Education Act is no longer good law. The en banc Third Circuit rejected that rule in A.W. v. Jersey City Public Schools; the Tenth Circuit had earlier declined to follow it.
More on how this was screened

A.W. also rejected a Section 1983 route for Section 504 violations. These rulings do not decide Matula's separate holding about the administrative settlement. All 71 flagged citations have been read. The 2 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.

71 later cases cite W.B. v. Matula; 71 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 W.B. v. Matula?

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 en banc Third Circuit rejected Matula's holding that violations of IDEA-created rights are actionable under Section 1983.

    A.W. v. Jersey City Public Schools · Third Circuit (en banc) · filed

    Here, the District Court followed our decision in Matula, where we held that violations of IDEA-created rights are actionable under § 1983. ... we now conclude that we should not continue to adhere to the principle we established in Matula.
    Read the full opinion on CourtListener →

Declined to follow

  • The Tenth Circuit rejected Matula's rule permitting an IDEA violation to support a Section 1983 claim.

    Padilla v. School District No. 1 · Tenth Circuit · filed

    This difficult question has created a split in the circuits. Compare, e.g. , Marie O. v. Edgar , 131 F.3d 610, 622 (7th Cir. 1997) ... and W.B. v. Matula , 67 F.3d 484, 494 (3d Cir. 1995) (same), with Sellers v. Sch. Bd. , 141 F.3d 524, 530-32 (4th Cir. 1998) ... We agree with the Fourth Circuit that § 1415(f) left intact Smith ’s implication that the EHA may not provide the basis for § 1983 claims.
    Read the full opinion on CourtListener →

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