Case Citator › Supreme Tribe of Ben-Hur v. Cauble

Supreme Tribe of Ben-Hur v. Cauble

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

Overruled in part
Court
Supreme Court of the United States
Citation
255 U.S. 356
Decided
Confirmed treatments
2
Flagged citations read
19 of 19
Treatment dates
1941–2008
Overruled in part
A reviewed court has overruled part of this case’s holding. Overruled in part. Toucey v. New York Life Insurance Co. rejected Ben-Hur's ruling that a federal court could enjoin state suits seeking to relitigate its class decree.
More on how this was screened

Later courts continued to apply Ben-Hur's separate rule that an adequately represented class decree binds absent members. The Class Action Fairness Act changed its named-representative citizenship rule for covered class actions. All 19 flagged citations have been read. The final citation appears in a dissent that reports Toucey's earlier overruling, so it adds no treatment by that court. The Constitution Annotated lists Toucey as the overruling decision.

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.

19 citations to Supreme Tribe of Ben-Hur v. Cauble 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 Supreme Tribe of Ben-Hur v. Cauble?

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 Supreme Court rejected Ben-Hur's allowance of a federal injunction against state suits relitigating a federal class decree.

    Toucey v. New York Life Insurance Co. · Supreme Court of the United States · filed

    Supreme Tribe of Ben-Hur v. Cauble, 255 U. S. 356, held that a federal district court, having rendered a decree in a class suit brought in behalf of all the members of a certain class of beneficiaries in a fraternal association, may enjoin members of the class, found to be bound by the decree, from prosecuting suits in the state courts which would relitigate questions settled by such decree. ... Loose language and a sporadic, ill-considered decision cannot be held to have imbedded in our law a doctrine which so patently violates the expressed prohibition of Congress.
    Read the full opinion on CourtListener →

Superseded by statute

  • The Fifth Circuit held that the Class Action Fairness Act allows diversity jurisdiction based on an unnamed class member's citizenship, displacing Ben-Hur's named-representative rule in covered actions.

    Louisiana v. AAA Insurance · Fifth Circuit · filed

    It signifies that CAFA, in expanding federal jurisdiction over certain class actions filed in state court, escaped the rule that citizenship of the named representative is controlling.14 ... Cf. Supreme Tribe of Ben Hur v. Cauble, 255 U.S. 356, 363-64, 41 S.Ct. 338, 65 L.Ed. 673 (1921)
    Read the full opinion on CourtListener →

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