Case Citator › Chin v. Port Authority of New York & New Jersey

Chin v. Port Authority of New York & New Jersey

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

Superseded by statute
Court
Second Circuit
Citation
685 F.3d 135
Decided
Confirmed treatments
1
Flagged citations read
54 of 54
Citing cases (total)
54
Treatment dates
2021

Status

Superseded by statute
A reviewed court treats this case as superseded by later legislation. Chin v. Port Authority of New York & New Jersey's spoliation standard was superseded for electronically stored information. Mule v. 3-D Building and Construction Management Corp. held that the 2015 amendment to Federal Rule of Civil Procedure 37(e) supplies a different standard for lost electronic evidence; Chin's traditional standard remains relevant to tangible evidence.
More on how this was screened

Its rulings on discrimination claims continue to be cited. All 54 flagged citations have been read; the one confirmed adverse treatment is 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.

54 later cases cite Chin v. Port Authority of New York & New Jersey; 54 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 Chin v. Port Authority of New York & New Jersey?

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Treatments

Superseded by statute

  • The court held that amended Rule 37(e) replaced the traditional spoliation standard cited in Chin for electronically stored information, while tangible evidence remains subject to a separate analysis.

    Mule v. 3-D Building and Construction Management Corp. · E.D.N.Y. · filed

    Chin v. Port Auth. of New York and New Jersey, 685 F.3d 135, 162 (2d Cir. 2012) ... “This general rule applied to the destruction of both tangible and electronic evidence until December 1, 2015, at which time Rule 37(e) of the Federal Rules of Civil Procedure was amended to provide a different standard for the destruction of ESI.”
    Read the full opinion on CourtListener →

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