Case Citator › McClelland v. Gronwaldt

McClelland v. Gronwaldt

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

Overruled in part
Court
Fifth Circuit
Citation
155 F.3d 507
Decided
Confirmed treatments
1
Flagged citations read
29 of 29
Citing cases (total)
29
Treatment dates
2003
Overruled in part
A reviewed court has overruled part of this case’s holding. McClelland v. Gronwaldt was overruled in part: all 29 flagged citations have been read, and the confirmed treatment is listed below. The Fifth Circuit's en banc decision in Arana v. Ochsner Health Plan rejected McClelland's requirement that a claim be subject to ERISA conflict preemption before it can support removal through complete preemption.
More on how this was screened

Later courts continue to cite McClelland on other points, including supplemental jurisdiction after federal claims end.

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.

29 later cases cite McClelland v. Gronwaldt; 29 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 McClelland v. Gronwaldt?

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 Fifth Circuit overruled McClelland's rule requiring ERISA conflict preemption in addition to complete preemption for federal removal jurisdiction.

    Arana v. Ochsner Health Plan · Fifth Circuit (en banc) · filed

    We thus hold that only complete preemption of a claim under ERISA § 502(a) is required for removal jurisdiction; conflict preemption under ERISA § 514 is not required;10 and we overrule the relevant portions of our precedent to the contrary.11 ... These portions of our precedent include: Heimann, 187 F.3d at 502; Copling, 174 F.3d . at 597 n. 14; McClelland, 155 F.3d at 517 & n. 31; Hurtle, 877 F.2d at 355.
    Read the full opinion on CourtListener →

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