James G. Jackson v. City of Columbus, Gregory Lashutka, Thomas W. Rice, Sr.
Is it still good law? What later courts have actually done to this case.
Status
114 later cases cite James G. Jackson v. City of Columbus, Gregory Lashutka, Thomas W. Rice, Sr.; 114 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 James G. Jackson v. City of Columbus, Gregory Lashutka, Thomas W. Rice, Sr.?
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
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Swierkiewicz rejected Jackson's heightened discrimination-pleading rule.
Swierkiewicz v. Sorema N.A. · Supreme Court of the United States · filed
We hold that an employment discrimination complaint need not include such facts.
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Limited
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The Sixth Circuit held that Jackson did not settle whether a workplace search could reach an employee's locked personal safe.
Sylvia James v. Hilliard Hampton · Sixth Circuit · filed
However, unlike in Jackson, James alleges that a locked personal item — her safe— was also searched, and thus Jackson does not settle the question of whether the search was unreasonable in scope. As discussed above, James has alleged that she purchased the safe, maintained it for her personal use, and kept it under lock and key. These facts are sufficient to establish a plausible claim that it was excessively intrusive to search her personal safe, because evidence of work-related misconduct was unlikely to be found there.
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Questioned
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The Sixth Circuit said Muldrow called Jackson's paid-leave employment precedent into doubt, but reserved the issue because the plaintiff forfeited it.
Shannon Blick v. Ann Arbor Public School District · Sixth Circuit · filed
Like most courts, we have also long held that an employer does not take a materially adverse action when it temporarily suspends an employee with full pay while “timely” investigating the employee’s potential misconduct. White, 364 F.3d at 803; Peltier v. United States, 388 F.3d 984, 988 (6th Cir. 2004); see Sensabaugh v. Halliburton, 937 F.3d 621, 628–29 (6th Cir. 2019); Jackson, 194 F.3d at 752; see also Davis v. Legal Servs. Ala., Inc., 19 F.4th 1261, 1266–67 (11th Cir. 2021) (per curiam) (citing cases). So the district court dismissed Blick’s claim because the School District continued to pay her on leave. See Blick, 516 F. Supp. 3d at 721–24. A recent Supreme Court decision calls this rationale (and our precedent) into doubt. See Muldrow v. City of St. Louis, 144 S. Ct. 967, 974–77 (2024).
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Does this case still carry your argument?
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