Michael T. Byrne v. Camran Nezhat, M.D.
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
Later Eleventh Circuit panels and district courts repeatedly recognize that abrogation on other grounds while continuing to apply Byrne's recusal, pleading, and sanctions rules. The other nearby language concerned different authorities or rulings.
115 citations to Michael T. Byrne v. Camran Nezhat, M.D. 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 Michael T. Byrne v. Camran Nezhat, M.D.?
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 Supreme Court abrogated Byrne's rule that a civil RICO plaintiff alleging mail fraud must show reliance on the defendant's misrepresentation, holding that first-party reliance is neither an element of the claim nor a prerequisite to proximate causation.
Bridge v. Phoenix Bond & Indemnity Co. · Supreme Court of the United States · filed
For the foregoing reasons, we hold that a plaintiff asserting a RICO claim predicated on mail fraud need not show, either as an element of its claim or as a prerequisite to establishing proximate causation, that it relied on the defendant’s alleged misrepresentations.
Read the full opinion on CourtListener →
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