United Phosphorus, Ltd. v. Angus Chemical Company
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
Later opinions generally continued to apply United Phosphorus's unaffected Rule 12(b)(1) framework while reporting Minn-Chem's treatment in history parentheticals; those history reports are not additional treatments.
126 citations to United Phosphorus, Ltd. v. Angus Chemical Company 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.
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Treatments
Overruled
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The en banc Seventh Circuit held that the FTAIA's criteria concern the merits of an antitrust claim rather than subject-matter jurisdiction and expressly overruled United Phosphorus's contrary holding.
Minn-Chem, Inc. v. Agrium Inc. · Seventh Circuit (en banc) · filed
We hold first that the FTAIA’s criteria relate to the merits of a claim, and not to the subject-matter jurisdiction of the court. We therefore overrule our earlier en banc deci- sion in United Phosphorus, Ltd. v. Angus Chem. Co., 322 F.3d 942 (7th Cir. 2003).
Read the full opinion on CourtListener →
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