Case Citator › Jane Marie Egerdahl v. Hibbing Community College Minnesota Community College System State of Minnesota Myron Schmidt Anthony Kuznik and Jerry Krause

Jane Marie Egerdahl v. Hibbing Community College Minnesota Community College System State of Minnesota Myron Schmidt Anthony Kuznik and Jerry Krause

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

Overruled in part
Court
Eighth Circuit
Citation
72 F.3d 615
Decided
Confirmed treatments
1
Flagged citations read
151 of 151
Citing cases (total)
645
Treatment dates
2025
Overruled in part
A reviewed court has overruled part of this case’s holding. Jane Marie Egerdahl v. Hibbing Community College Minnesota Community College System State of Minnesota Myron Schmidt Anthony Kuznik and Jerry Krause is overruled in part by the confirmed treatment listed below. All 151 flagged citations have been read.
More on how this was screened

The en banc Eighth Circuit discarded Egerdahl's clear-statement rule for determining whether a § 1983 defendant was sued in an individual or official capacity and replaced it with the course-of-proceedings test. Later opinions continue to apply Egerdahl's unaffected limitations and sovereign-immunity holdings; their abrogation parentheticals report the en banc decision rather than independently treating Egerdahl.

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.

645 later cases cite Jane Marie Egerdahl v. Hibbing Community College Minnesota Community College System State of Minnesota Myron Schmidt Anthony Kuznik and Jerry Krause; 151 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 Marie Egerdahl v. Hibbing Community College Minnesota Community College System State of Minnesota Myron Schmidt Anthony Kuznik and Jerry Krause?

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 Eighth Circuit overruled Egerdahl's rule that a § 1983 complaint silent about capacity asserts only official-capacity claims, replacing it with the course-of-proceedings test.

    S.A.A. v. Geisler · Eighth Circuit (en banc) · filed

    Sitting en banc, we discard our clear statement rule and adopt the “course of proceedings test” for determining whether a § 1983 defendant is sued in her individual or official capacity.
    Read the full opinion on CourtListener →

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