Case Citator › Smith v. Allen

Smith v. Allen

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

Overruled in part
Court
Eleventh Circuit
Citation
502 F.3d 1255
Decided
Confirmed treatments
3
Flagged citations read
104 of 104
Citing cases (total)
104
Treatment dates
2008–2021
Overruled in part
A reviewed court has overruled part of this case’s holding. Smith v. Allen has been overruled in part. All 104 flagged citations have been read; three confirmed adverse treatments are listed below.
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.

104 later cases cite Smith v. Allen; 104 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 Smith v. Allen?

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 Eleventh Circuit overruled Smith to the extent it held that the PLRA precludes punitive damages absent physical injury.

    Conraad L. Hoever v. R. Marks · Eleventh Circuit · filed

    A subsequent panel then relied on Napier for the proposition that compensatory and punitive damages “are precluded under the PLRA” absent physical injury. Smith v. Allen, 502 F.3d 1255, 1271 (11th Cir. 2007), abrogated on other grounds by Sossamon v. Texas, 563 U.S. 277, 131 S. Ct. 1651 (2011). ... Because this Court’s precedents did not grapple meaningfully with the text of § 1997e(e), we now overrule those precedents in this regard.
    Read the full opinion on CourtListener →

Abrogated

  • The Supreme Court abrogated Smith's holding that a state accepting federal funds waives sovereign immunity from private suits for money damages under RLUIPA.

    Sossamon v. Texas · Supreme Court of the United States · filed

    We conclude that States, in accepting federal funding, do not consent to waive their sovereign immunity to private suits for money damages under RLUIPA because no statute expressly and unequivocally includes such a waiver. The judgment of the United States Court of Appeals for the Fifth Circuit is affirmed.
    Read the full opinion on CourtListener →

Declined to follow

  • The District of Connecticut declined to follow Smith's conclusion that RLUIPA's authorization of “appropriate relief” clearly permits money damages against a state.

    El Badrawi v. Department of Homeland Security · D. Conn. · filed

    In concluding that the phrase “appropriate relief’ encompassed an award of money damages, the Eleventh Circuit reasoned that, “where Congress ha[s] not given any guidance or clear indication of its purpose with respect to remedies, federal courts should presume the availability of all appropriate remedies.” Smith, 502 F.3d at 1270 (citing Franklin v. Gwinnett County Public Sch., 503 U.S. 60, 68-69, 112 S.Ct. 1028, 117 L.Ed.2d 208 (1992)). This reasoning is unpersuasive because the court failed to account for the special, clear statement rules that apply when the federal government seeks to abrogate state sovereign immunity.
    Read the full opinion on CourtListener →

Does this case still carry your argument?

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