Case Citator › Standard v. A.B.E.L. Services, Inc.

Standard v. A.B.E.L. Services, Inc.

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

Overruled in part
Court
Eleventh Circuit
Citation
161 F.3d 1318
Decided
Confirmed treatments
1
Flagged citations read
41 of 41
Citing cases (total)
41
Treatment dates
2006
Overruled in part
A reviewed court has overruled part of this case’s holding. Standard v. A.B.E.L. Services, Inc. has been displaced in part on the scope of actionable retaliation; its separate discrimination and pretext rules remain in use.
More on how this was screened

All 41 flagged citations have been read. Burlington Northern & Santa Fe Railway Co. v. White held that Title VII retaliation can include materially adverse harm outside the workplace, rejecting the narrower employment-action premise reflected in Standard's retaliation framework. The Eleventh Circuit later described Standard as “abrogated on other grounds by Burlington” in Berry v. Crestwood Healthcare LP. That confirmed treatment is listed below. The other citing opinions applied Standard or repeated that history without themselves changing its rule.

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.

41 later cases cite Standard v. A.B.E.L. Services, Inc.; 41 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 Standard v. A.B.E.L. Services, Inc.?

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 rejected the premise that retaliation must alter employment conditions, displacing Standard's adverse-employment-action formulation for retaliation while leaving its other holdings untouched.

    Burlington Northern & Santa Fe Railway Co. v. White · Supreme Court of the United States · filed

    For these reasons, we conclude that Title VII’s substantive provision and its antiretaliation provision are not coterminous. The scope of the antiretaliation provision extends beyond workplace-related or employment-related retaliatory acts and harm. We therefore reject the standards applied in the Courts of Appeals that have treated the antiretaliation provision as forbidding the same conduct prohibited by the antidiscrimination provision and that have limited actionable retaliation to so-called “ultimate employment decisions.”
    Read the full opinion on CourtListener →

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