Case Citator › Edwards v. City of Goldsboro

Edwards v. City of Goldsboro

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

Declined by some courts
Court
Fourth Circuit
Citation
178 F.3d 231
Decided
Confirmed treatments
1
Flagged citations read
73 of 73
Citing cases (total)
73
Treatment dates
2018
Declined by some courts
At least one reviewed court has declined to follow this case. No reviewed court has overruled it. The Third Circuit declined to follow Edwards v. City of Goldsboro on the public concern requirement for a public employee’s union affiliation claim. All 73 flagged citations have been read.
More on how this was screened

Other courts applied Edwards’s rules on pleading, amendment, appellate forfeiture, qualified immunity, and review of motions for judgment on the pleadings. The entry below uses Palardy's September 28 filing date. No other adverse treatment was confirmed.

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.

73 later cases cite Edwards v. City of Goldsboro; 73 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 Edwards v. City of Goldsboro?

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

Declined to follow

  • The Third Circuit held that a public employee need not show a matter of public concern for a First Amendment association claim based on union affiliation, rejecting the rule it attributed to Edwards in that context.

    Palardy v. Township of Millburn · Third Circuit · filed

    The Second, Fourth, Sixth, and Seventh Circuits apply the public concern requirement to public employee association claims. See Cobb v. Pozzi, 363 F.3d 89, 107 (2d Cir. 2004); Edwards v. City of Goldsboro, 178 F.3d 231, 249- 50 (4th Cir. 1999); Boals v. Gray, 775 F.2d 686, 692 (6th Cir. 1985); Klug v. Chi. Sch. Reform Bd. of Trs., 197 F.3d 853, 857 (7th Cir. 1999). ... In this specific context—an associational claim arising from a public employee’s union affiliation—the minority position followed by the Fifth Circuit is the better one.
    Read the full opinion on CourtListener →

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