Stephanie J. Quinn v. Green Tree Credit Corporation
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
The Second Circuit recorded Morgan's partial abrogation of Quinn in Andersen v. Rochester City School District (2012). Later courts continued to apply Quinn's other harassment and retaliation rulings.
52 later cases cite Stephanie J. Quinn v. Green Tree Credit Corporation; 52 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 Stephanie J. Quinn v. Green Tree Credit Corporation?
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 replaced Quinn's earlier continuing violation framework for Title VII claims: a hostile work environment may include related acts outside the filing period if one contributing act is timely, while each discrete act needs its own timely charge.
National Railroad Passenger Corp. v. Morgan · Supreme Court of the United States · filed
We hold that the statute precludes recovery for discrete acts of discrimination or retaliation that occur outside the statutory time period. We also hold that consideration of the entire scope of a hostile work environment claim, including behavior alleged outside the statutory time period, is permissible for the purposes of assessing liability, so long as an act contributing to that hostile environment takes place within the statutory time period.
Read the full opinion on CourtListener →
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