Case Citator › Beck v. Haik

Beck v. Haik

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

Overruled in part
Court
Sixth Circuit
Citation
377 F.3d 624
Decided
Confirmed treatments
2
Flagged citations read
40 of 40
Citing cases (total)
40
Treatment dates
2009–2020
Overruled in part
A reviewed court has overruled part of this case’s holding. Beck v. Haik has been overruled in part. All 40 flagged citations have been read.
More on how this was screened

The 2 confirmed treatments listed below concern its use of state law for spoliation sanctions and its allocation of the burden to show harmless error in civil cases. Later courts continue to cite Beck on other issues, including its fair-assurance review of trial errors.

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.

40 later cases cite Beck v. Haik; 40 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 Beck v. Haik?

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

  • Sitting en banc, the Sixth Circuit overruled Beck's rule that state law controls sanctions for spoliated evidence in federal court.

    Adkins v. Wolever · Sixth Circuit (en banc) · filed

    The original panel, constrained by our earlier opinions that applied state law to determine whether spoliation sanctions were available, (see, e.g., Beck v. Haik, 377 F.3d 624, 641 (6th Cir.2004); ...), affirmed the district court’s denial of sanctions because applicable state law did not provide for sanctions based on third-party spoliation. ... To the extent that our earlier opinions held otherwise, we overrule them.
    Read the full opinion on CourtListener →

  • The Sixth Circuit held that Beck's allocation of the burden to prove harmless error in a civil case did not survive an intervening Supreme Court decision.

    A. K. v. Durham School Services, L.P. · Sixth Circuit · filed

    To the extent that Beck and subsequent published decisions of this court, see, e.g., Griffin v. Finkbeiner, 689 F.3d 584, 599 (6th Cir. 2012); Tamraz v. Lincoln Elec. Co., 620 F.3d 665, 676 (6th Cir. 2010); Mike’s Train House, Inc. v. Lionel, L.L.C., 472 F.3d 398, 409–10 (6th Cir. 2006), endorsed this allocation of the burden for civil cases, the rule does not survive Shinseki.
    Read the full opinion on CourtListener →

Does this case still carry your argument?

Describe your facts. Ezel reads Beck v. Haik and the cases that treated it, then tells you whether it still holds for your situation, with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace