Holifield v. Reno
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
The en banc Eleventh Circuit replaced Holifield's “same or similar” wording with a requirement that comparators be similarly situated in all material respects. That treatment is listed below; the opinion's other Title VII rulings were not displaced by this decision.
66 later cases cite Holifield v. Reno; 66 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 Holifield v. Reno?
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
Abrogated
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The en banc Eleventh Circuit replaced Holifield's “same or similar” comparator standard with a requirement that comparators be similarly situated in all material respects.
Jacqueline Lewis v. City of Union City, Georgia · Eleventh Circuit (en banc) · filed
In still others, without even mentioning the nearly-identical benchmark, we have deemed it sufficient that the plaintiff and the comparator engaged in the “same or similar” conduct. See, e.g., Holifield v. Reno, 115 F.3d 1555, 1562 (11th Cir. 1997) (per curiam). ... With respect to the standard itself, we hold that the proper test for evaluating comparator evidence is neither plain-old “same or similar” nor “nearly identical,” as our past cases have discordantly suggested. ... must demonstrate that she and her proffered comparators were “similarly situated in all material respects.”
Read the full opinion on CourtListener →
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