Case Citator › Adams v. California Department of Health Services

Adams v. California Department of Health Services

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

Overruled in part
Court
Ninth Circuit
Citation
487 F.3d 684
Decided
Confirmed treatments
1
Flagged citations read
348 of 348
Treatment dates
2008
Overruled in part
A reviewed court has overruled part of this case’s holding. Adams v. California Department of Health Services is overruled in part: all 348 flagged citations have been read, with the one confirmed treatment listed below. Taylor v. Sturgell rejected the broad virtual-representation exception that Adams adopted from Kourtis v. Cameron.
More on how this was screened

The Ninth Circuit and lower courts have since described Adams as overruled or abrogated on that other ground while continuing to apply its distinct rule against duplicative actions by the same plaintiff. The other reviewed opinions applied that surviving claim-splitting rule, copied parentheticals reporting Taylor's act, or placed unrelated treatment language near the citation. Duplicate copies of the same opinion do not create duplicate entries.

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.

348 citations to Adams v. California Department of Health Services 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 in Part

  • The Supreme Court rejected the broad virtual-representation theory Adams used to bind new defendants as privies, while leaving Adams's same-plaintiff claim-splitting rule intact.

    Taylor v. Sturgell · Supreme Court of the United States · filed

    We disapprove the doctrine of preclusion by “virtual representation,” and hold, based on the record as it now stands, that the judgment against Herrick does not bar Taylor from maintaining this suit. ... The Ninth Circuit applies a five-factor test similar to the D. C. Circuit’s. See Kourtis v. Cameron, 419 F. 3d 989, 996 (2005).
    Read the full opinion on CourtListener →

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