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9 California opinions name it 2 courts 1990–2025 3 in the last five years
The cases below were cited by California courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Krieger v. Nick Alexander Imports, Inc.green1 sentence2025(See, e.g., Krieger v. Nick Alexander Imports, Inc. (1991) 234 Cal.App.3d 205, 210 [the plaintiff brought Song-Beverly Act claim and claim for misrepresentation].) In either case, the choice of law provision might well be enforceable. | 1 | 1 |
Outboard Marine Corp. v. Superior Courtgreen1 sentence2022“The conduct that violates [Vehicle Code] section 11711, i.e., fraud or fraudulent representation, falls within the CLRA.” (Pierce v. Western Surety Co. (2012) 207 Cal.App.4th 83, 91-92 .) Thus, “plaintiffs routinely plead fraud, [unfair competition law], and CLRA claims based on similar allegations.” (Flores v. Southcoast Automotive Liquidators, Inc. (2017) 17 Cal.App.5th 841, 850 ; see Outboard Marine Corp. v. Superior Court (1975) 52 Cal.App.3d 30, 35-38 [plaintiff may allege both a common law fraud claim and CLRA claim based upon same facts].) However, simply because an act of actual fraud | 1 | 1 |
District Lodge No. 166, International Ass'n of Machinists v. TWA Services, Inc.green1 sentence2009Ass’n of Mach. v. TWA (11th Cir. 1984) 731 F.2d 711, 714-716 (District Lodge).) In Danielsen , employees of contractors providing services to the United States Navy initiated SCA administrative proceedings, alleging that their employers’ contracts misclassified them under the governing wage determinations. ( Danielsen, supra, 941 F.2d at pp. 1225-1226.) Before the conclusion of the SCA proceedings, the employees commenced an action against then-employers in federal district court, asserting RICO (Racketeer Influenced and Corrupt Organizations Act) claims ( 18 U.S.C. § 1962 et seq.) and a commo | 1 | 1 |
United States v. Peter MacKbygreen1 sentence2005(See Rex Trailer Co. v. United States (1956) 350 U.S. 148, 150 [ 100 L.Ed. 149 , 76 S.Ct. 219 ] [action for recovery under the Surplus Property Act predicated upon false statements made in obtaining government property]; U.S. v. Mackby (9th Cir. 2003) 339 F.3d 1013, 1018 [action under the FFCA involving fraudulent demands for Medicare reimbursement]; Bly-Magee v. California (9th Cir. 2001) 236 F.3d 1014 , 1017 [qui tarn action under the FFCA seeking to recover allegedly misappropriated federal funds made available to the State of California for vocational rehabilitation services].) Although th | 1 | 1 |
Rex Trailer Co. v. United Statesgreen2 sentences2005(See Rex Trailer Co. v. United States (1956) 350 U.S. 148, 150 [ 100 L.Ed. 149 , 76 S.Ct. 219 ] [action for recovery under the Surplus Property Act predicated upon false statements made in obtaining government property]; U.S. v. Mackby (9th Cir. 2003) 339 F.3d 1013, 1018 [action under the FFCA involving fraudulent demands for Medicare reimbursement]; Bly-Magee v. California (9th Cir. 2001) 236 F.3d 1014 , 1017 [qui tarn action under the FFCA seeking to recover allegedly misappropriated federal funds made available to the State of California for vocational rehabilitation services].) Although th 2005(See Rex Trailer Co. v. United States (1956) 350 U.S. 148, 150 [ 100 L.Ed. 149 , 76 S.Ct. 219 ] [action for recovery under the Surplus Property Act predicated upon false statements made in obtaining government property]; U.S. v. Mackby (9th Cir. 2003) 339 F.3d 1013, 1018 [action under the FFCA involving fraudulent demands for Medicare reimbursement]; Bly-Magee v. California (9th Cir. 2001) 236 F.3d 1014 , 1017 [qui tarn action under the FFCA seeking to recover allegedly misappropriated federal funds made available to the State of California for vocational rehabilitation services].) Although th | 1 | 1 |
Chanoff v. United States Surgical Corp.green2 sentences2003(See Chanoff, supra, 857 F.Supp. at p. 1018 [rejecting claim that the timing of the disclosure caused damage].) Plaintiff contends the drop in Fritz’s stock price was more dramatic on July 24 because Fritz simultaneously announced its restated third quarter and disappointing fourth quarter results. 2003(See Chanoff, supra, 857 F.Supp. at p. 1018 [rejecting claim that the timing of the disclosure caused damage].) Plaintiff contends the drop in Fritz's stock price was more dramatic on July 24 because Fritz simultaneously announced its restated third quarter and disappointing fourth quarter results. | 1 | 1 |
Arnlund v. Deloitte & Touche LLPgreen2 sentences2003(See Arnlund v. Deloitte & Touche LLP (E.D.Va. 2002) 199 F.Supp.2d 461, 489 (Arnlund) [finding that stockholders who allegedly held their stock in reliance on the defendant’s public misrepresentations cannot, as a matter of law, state a common law fraud claim, because they failed “adequately to plead causation between the misrepresentation and the harm”].) Second, plaintiff suffered no cognizable injury from the timing of the announcement of Fritz’s true third quarter results. 2003(See Arnlund v. Deloitte & Touche LLP (E.D.Va.2002) 199 F.Supp.2d 461, 489 (Arnlund) [finding that stockholders who allegedly held their stock in reliance on the defendant's public misrepresentations cannot, as a matter of law, state a common law fraud claim, because they failed "adequately to plead causation between the misrepresentation and the harm"].) Second, plaintiff suffered no cognizable injury from the timing of the announcement of Fritz's true third quarter results. | 1 | 1 |
Banco Do Brasil, S.A. v. Latian, Inc.red2 sentences2002“The resolution of the issue of whether the [parol evidence] rule applies so as to exclude any collateral oral agreement is one of law to be determined by the court.” (Banco Do Brasil, S.A. v. Latian, Inc. (1991) 234 Cal.App.3d 973, 1001 [ 285 Cal.Rptr. 870 ].) The theory underlying the Wangs’ common law fraud claim for damages involves the affirmance of the lease contract, and not its rescission. “[T]he eminent Bernard E. 2002“The resolution of the issue of whether the [parol evidence] rule applies so as to exclude any collateral oral agreement is one of law to be determined by the court.” (Banco Do Brasil, S.A. v. Latian, Inc. (1991) 234 Cal.App.3d 973, 1001 [ 285 Cal.Rptr. 870 ].) The theory underlying the Wangs’ common law fraud claim for damages involves the affirmance of the lease contract, and not its rescission. “[T]he eminent Bernard E. | 1 | 1 |
Michael Kolentus v. Avco Corporation and Avco Precision Products Division, Avco Corporation, and Chemical Bankgreen1 sentence1990These are the types of claims to which the Garmon preemption doctrine was intended to apply.” (Parker v. Connors Steel Co. (11th Cir. 1988) 855 F.2d 1510, 1516-1517 , rehg. den. (1988) 864 F.2d 795 , cert. den. (1989) 490 U.S. 1066 [ 104 L.Ed.2d 631 , 109 S.Ct. 2066 ]; accord Kolentus v. Avco Corp. (7th Cir. 1986) 798 F.2d 949, 961 , cert. den. (1987) 479 U.S. 1032 [ 93 L.Ed.2d 832 , 107 S.Ct. 878 ] [“The plaintiffs’ common law fraud claim [regarding *1409 failure to provide accurate information about an impending plant closure] is indistinguishable from an unfair labor practice claim that cou | 1 | 1 |
Kolentus v. Avco Corp.green2 sentences1990These are the types of claims to which the Garmon preemption doctrine was intended to apply.” (Parker v. Connors Steel Co. (11th Cir. 1988) 855 F.2d 1510, 1516-1517 , rehg. den. (1988) 864 F.2d 795 , cert. den. (1989) 490 U.S. 1066 [ 104 L.Ed.2d 631 , 109 S.Ct. 2066 ]; accord Kolentus v. Avco Corp. (7th Cir. 1986) 798 F.2d 949, 961 , cert. den. (1987) 479 U.S. 1032 [ 93 L.Ed.2d 832 , 107 S.Ct. 878 ] [“The plaintiffs’ common law fraud claim [regarding *1409 failure to provide accurate information about an impending plant closure] is indistinguishable from an unfair labor practice claim that cou 1990These are the types of claims to which the Garmon preemption doctrine was intended to apply.” (Parker v. Connors Steel Co. (11th Cir. 1988) 855 F.2d 1510, 1516-1517 , rehg. den. (1988) 864 F.2d 795 , cert. den. (1989) 490 U.S. 1066 [ 104 L.Ed.2d 631 , 109 S.Ct. 2066 ]; accord Kolentus v. Avco Corp. (7th Cir. 1986) 798 F.2d 949, 961 , cert. den. (1987) 479 U.S. 1032 [ 93 L.Ed.2d 832 , 107 S.Ct. 878 ] [“The plaintiffs’ common law fraud claim [regarding *1409 failure to provide accurate information about an impending plant closure] is indistinguishable from an unfair labor practice claim that cou | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in California. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Lacher v. Superior Court
green
1 sentence2022“Civil Code section 1770 describes 24 separate acts that may constitute a CLRA violation.” (Pierce, at p. 91.) Most of these acts would not rise to the level of fraud or fraudulent representation because “ ‘[f]raud is an intentional tort’ ” (Lacher v. Superior Court (1991) 230 Cal.App.3d 1038, 1046 ; see Civ. | 1 | 2022–2022 |
Flores v. Southcoast Auto. Liquidators, Inc.
green
1 sentence2022“The conduct that violates [Vehicle Code] section 11711, i.e., fraud or fraudulent representation, falls within the CLRA.” (Pierce v. Western Surety Co. (2012) 207 Cal.App.4th 83, 91-92 .) Thus, “plaintiffs routinely plead fraud, [unfair competition law], and CLRA claims based on similar allegations.” (Flores v. Southcoast Automotive Liquidators, Inc. (2017) 17 Cal.App.5th 841, 850 ; see Outboard Marine Corp. v. Superior Court (1975) 52 Cal.App.3d 30, 35-38 [plaintiff may allege both a common law fraud claim and CLRA claim based upon same facts].) However, simply because an act of actual fraud | 1 | 2022–2022 |
American Air Equipment, Inc. v. Pacific Employers Insurance
green
1 sentence2022(Beverly Finance Co., supra, 273 Cal.App.2d. at p. 268; American Air Equipment, supra, 37 Cal.App.3d. at p. 327.) 7 We recognize there are situations in which the same factual allegations might give rise to liability under both statutory schemes. | 1 | 2022–2022 |
Robinson Helicopter Co., Inc. v. Dana Corp.
green
1 sentence2022The trial court sustained Nissan’s demurrer to the fraudulent inducement claim (the fourth cause of action in the SAC) without leave to amend, holding the claim was barred by the “economic loss rule” discussed in Robinson Helicopter Co., Inc. v. Dana Corp. (2004) 34 Cal.4th 979 (Robinson). | 1 | 2022–2022 |
Pierce v. Western Surety Co.
green
1 sentence2022“The conduct that violates [Vehicle Code] section 11711, i.e., fraud or fraudulent representation, falls within the CLRA.” (Pierce v. Western Surety Co. (2012) 207 Cal.App.4th 83, 91-92 .) Thus, “plaintiffs routinely plead fraud, [unfair competition law], and CLRA claims based on similar allegations.” (Flores v. Southcoast Automotive Liquidators, Inc. (2017) 17 Cal.App.5th 841, 850 ; see Outboard Marine Corp. v. Superior Court (1975) 52 Cal.App.3d 30, 35-38 [plaintiff may allege both a common law fraud claim and CLRA claim based upon same facts].) However, simply because an act of actual fraud | 1 | 2022–2022 |
Committee on Children's Television, Inc. v. General Foods Corp.
red
1 sentence2014(Committee on Children’s Television, Inc. v. General Foods Corp., supra, 35 Cal.3d at pp. 212-213; Morgan, supra, 177 Cal.App.4th at p. 1256 .) However, Harris fails to explain how, under the UCL, she has properly pled a cause of action for fraudulent business practices. | 1 | 2014–2014 |
Morgan v. AT&T Wireless Services, Inc.
green
2 sentences2014(Committee on Children’s Television, Inc. v. General Foods Corp., supra, 35 Cal.3d at pp. 212-213; Morgan, supra, 177 Cal.App.4th at p. 1256 .) However, Harris fails to explain how, under the UCL, she has properly pled a cause of action for fraudulent business practices. 2014(Committee on Children’s Television, Inc. v. General Foods Corp., supra, 35 Cal.3d at pp. 212-213; Morgan, supra, 177 Cal.App.4th at p. 1256 .) However, Harris fails to explain how, under the UCL, she has properly pled a cause of action for fraudulent business practices. | 1 | 2014–2014 |
Lloyd T. Danielsen v. Burnside-Ott Aviation Training Center, Inc.
green
2 sentences2009(Danielsen, supra, 941 F.2d at p. 1226 .) The District of Columbia Circuit, following the Ninth Circuit’s reasoning in MSW, concluded that the SCA provided the exclusive remedy to enforce its provisions, and that “[a] private civil action, even couched in RICO terms, will not lie for an alleged breach of the SCA.” (Danielsen, supra, 941 F.2d at p. 1229 ; accord, *664 District Lodge, supra, 731 F.2d at pp. 714-716 [following Ninth Circuit’s determination in MSW that “Congress did not intend to authorize private suits to enforce the [SCA]”].) Nonetheless, the absence of a private right to enforc 2009(Danielsen, supra, 941 F.2d at p. 1226 .) The District of Columbia Circuit, following the Ninth Circuit’s reasoning in MSW, concluded that the SCA provided the exclusive remedy to enforce its provisions, and that “[a] private civil action, even couched in RICO terms, will not lie for an alleged breach of the SCA.” (Danielsen, supra, 941 F.2d at p. 1229 ; accord, *664 District Lodge, supra, 731 F.2d at pp. 714-716 [following Ninth Circuit’s determination in MSW that “Congress did not intend to authorize private suits to enforce the [SCA]”].) Nonetheless, the absence of a private right to enforc | 1 | 2009–2009 |
United States v. Halper
red
1 sentence2005(Halper, supra, 490 U.S. at p. 445 .) It did not hold that investigation costs of a claim that is outside the purview of that statute are reimbursable under the statute, or that investigation costs transmute a common law fraud claim into an FFCA claim. 3 The Attorney General cites various cases which purportedly stand for the proposition that “federal courts find cognizable a claim under the [FFCA] if the false claim impairs the government’s achievement of public goals and objectives, irrespective of financial harm to the treasury.” However, the cited cases do not prove the Attorney General’s | 1 | 2005–2005 |
Bly-Magee v. California
green
1 sentence2005(See Rex Trailer Co. v. United States (1956) 350 U.S. 148, 150 [ 100 L.Ed. 149 , 76 S.Ct. 219 ] [action for recovery under the Surplus Property Act predicated upon false statements made in obtaining government property]; U.S. v. Mackby (9th Cir. 2003) 339 F.3d 1013, 1018 [action under the FFCA involving fraudulent demands for Medicare reimbursement]; Bly-Magee v. California (9th Cir. 2001) 236 F.3d 1014 , 1017 [qui tarn action under the FFCA seeking to recover allegedly misappropriated federal funds made available to the State of California for vocational rehabilitation services].) Although th | 1 | 2005–2005 |
United States Ex Rel. Hayes v. CMC Electronics Inc.
green
1 sentence2005(See Rex Trailer Co. v. United States (1956) 350 U.S. 148, 150 [ 100 L.Ed. 149 , 76 S.Ct. 219 ] [action for recovery under the Surplus Property Act predicated upon false statements made in obtaining government property]; U.S. v. Mackby (9th Cir. 2003) 339 F.3d 1013, 1018 [action under the FFCA involving fraudulent demands for Medicare reimbursement]; Bly-Magee v. California (9th Cir. 2001) 236 F.3d 1014 , 1017 [qui tarn action under the FFCA seeking to recover allegedly misappropriated federal funds made available to the State of California for vocational rehabilitation services].) Although th | 1 | 2005–2005 |
Serrano v. Jones & Laughlin Steel Co.
green
1 sentence1990These are the types of claims to which the Garmon preemption doctrine was intended to apply.” (Parker v. Connors Steel Co. (11th Cir. 1988) 855 F.2d 1510, 1516-1517 , rehg. den. (1988) 864 F.2d 795 , cert. den. (1989) 490 U.S. 1066 [ 104 L.Ed.2d 631 , 109 S.Ct. 2066 ]; accord Kolentus v. Avco Corp. (7th Cir. 1986) 798 F.2d 949, 961 , cert. den. (1987) 479 U.S. 1032 [ 93 L.Ed.2d 832 , 107 S.Ct. 878 ] [“The plaintiffs’ common law fraud claim [regarding *1409 failure to provide accurate information about an impending plant closure] is indistinguishable from an unfair labor practice claim that cou | 1 | 1990–1990 |
Parker v. Connors Steel Co.
neutral
1 sentence1990These are the types of claims to which the Garmon preemption doctrine was intended to apply.” (Parker v. Connors Steel Co. (11th Cir. 1988) 855 F.2d 1510, 1516-1517 , rehg. den. (1988) 864 F.2d 795 , cert. den. (1989) 490 U.S. 1066 [ 104 L.Ed.2d 631 , 109 S.Ct. 2066 ]; accord Kolentus v. Avco Corp. (7th Cir. 1986) 798 F.2d 949, 961 , cert. den. (1987) 479 U.S. 1032 [ 93 L.Ed.2d 832 , 107 S.Ct. 878 ] [“The plaintiffs’ common law fraud claim [regarding *1409 failure to provide accurate information about an impending plant closure] is indistinguishable from an unfair labor practice claim that cou | 1 | 1990–1990 |
Parker v. Connors Steel Co.
green
1 sentence1990These are the types of claims to which the Garmon preemption doctrine was intended to apply.” (Parker v. Connors Steel Co. (11th Cir. 1988) 855 F.2d 1510, 1516-1517 , rehg. den. (1988) 864 F.2d 795 , cert. den. (1989) 490 U.S. 1066 [ 104 L.Ed.2d 631 , 109 S.Ct. 2066 ]; accord Kolentus v. Avco Corp. (7th Cir. 1986) 798 F.2d 949, 961 , cert. den. (1987) 479 U.S. 1032 [ 93 L.Ed.2d 832 , 107 S.Ct. 878 ] [“The plaintiffs’ common law fraud claim [regarding *1409 failure to provide accurate information about an impending plant closure] is indistinguishable from an unfair labor practice claim that cou | 1 | 1990–1990 |
Reliance Insurance v. Glados, Inc.
neutral
1 sentence1990These are the types of claims to which the Garmon preemption doctrine was intended to apply.” (Parker v. Connors Steel Co. (11th Cir. 1988) 855 F.2d 1510, 1516-1517 , rehg. den. (1988) 864 F.2d 795 , cert. den. (1989) 490 U.S. 1066 [ 104 L.Ed.2d 631 , 109 S.Ct. 2066 ]; accord Kolentus v. Avco Corp. (7th Cir. 1986) 798 F.2d 949, 961 , cert. den. (1987) 479 U.S. 1032 [ 93 L.Ed.2d 832 , 107 S.Ct. 878 ] [“The plaintiffs’ common law fraud claim [regarding *1409 failure to provide accurate information about an impending plant closure] is indistinguishable from an unfair labor practice claim that cou | 1 | 1990–1990 |
In re Disbarment of Benjamin
neutral
1 sentence1990These are the types of claims to which the Garmon preemption doctrine was intended to apply.” (Parker v. Connors Steel Co. (11th Cir. 1988) 855 F.2d 1510, 1516-1517 , rehg. den. (1988) 864 F.2d 795 , cert. den. (1989) 490 U.S. 1066 [ 104 L.Ed.2d 631 , 109 S.Ct. 2066 ]; accord Kolentus v. Avco Corp. (7th Cir. 1986) 798 F.2d 949, 961 , cert. den. (1987) 479 U.S. 1032 [ 93 L.Ed.2d 832 , 107 S.Ct. 878 ] [“The plaintiffs’ common law fraud claim [regarding *1409 failure to provide accurate information about an impending plant closure] is indistinguishable from an unfair labor practice claim that cou | 1 | 1990–1990 |
| Serrano v. Jones & Laughlin Steel Co. neutral | 1 | 1990–1990 |
In re Disbarment of Clayton
neutral
1 sentence1990These are the types of claims to which the Garmon preemption doctrine was intended to apply.” (Parker v. Connors Steel Co. (11th Cir. 1988) 855 F.2d 1510, 1516-1517 , rehg. den. (1988) 864 F.2d 795 , cert. den. (1989) 490 U.S. 1066 [ 104 L.Ed.2d 631 , 109 S.Ct. 2066 ]; accord Kolentus v. Avco Corp. (7th Cir. 1986) 798 F.2d 949, 961 , cert. den. (1987) 479 U.S. 1032 [ 93 L.Ed.2d 832 , 107 S.Ct. 878 ] [“The plaintiffs’ common law fraud claim [regarding *1409 failure to provide accurate information about an impending plant closure] is indistinguishable from an unfair labor practice claim that cou | 1 | 1990–1990 |
Serrano v. Jones & Laughlin Steel Co.
neutral
2 sentences1990These are the types of claims to which the Garmon preemption doctrine was intended to apply.” (Parker v. Connors Steel Co. (11th Cir. 1988) 855 F.2d 1510, 1516-1517 , rehg. den. (1988) 864 F.2d 795 , cert. den. (1989) 490 U.S. 1066 [ 104 L.Ed.2d 631 , 109 S.Ct. 2066 ]; accord Kolentus v. Avco Corp. (7th Cir. 1986) 798 F.2d 949, 961 , cert. den. (1987) 479 U.S. 1032 [ 93 L.Ed.2d 832 , 107 S.Ct. 878 ] [“The plaintiffs’ common law fraud claim [regarding *1409 failure to provide accurate information about an impending plant closure] is indistinguishable from an unfair labor practice claim that cou 1990These are the types of claims to which the Garmon preemption doctrine was intended to apply.” (Parker v. Connors Steel Co. (11th Cir. 1988) 855 F.2d 1510, 1516-1517 , rehg. den. (1988) 864 F.2d 795 , cert. den. (1989) 490 U.S. 1066 [ 104 L.Ed.2d 631 , 109 S.Ct. 2066 ]; accord Kolentus v. Avco Corp. (7th Cir. 1986) 798 F.2d 949, 961 , cert. den. (1987) 479 U.S. 1032 [ 93 L.Ed.2d 832 , 107 S.Ct. 878 ] [“The plaintiffs’ common law fraud claim [regarding *1409 failure to provide accurate information about an impending plant closure] is indistinguishable from an unfair labor practice claim that cou | 1 | 1990–1990 |
Parker v. Connors Steel Co.
green
2 sentences1990These are the types of claims to which the Garmon preemption doctrine was intended to apply.” (Parker v. Connors Steel Co. (11th Cir. 1988) 855 F.2d 1510, 1516-1517 , rehg. den. (1988) 864 F.2d 795 , cert. den. (1989) 490 U.S. 1066 [ 104 L.Ed.2d 631 , 109 S.Ct. 2066 ]; accord Kolentus v. Avco Corp. (7th Cir. 1986) 798 F.2d 949, 961 , cert. den. (1987) 479 U.S. 1032 [ 93 L.Ed.2d 832 , 107 S.Ct. 878 ] [“The plaintiffs’ common law fraud claim [regarding *1409 failure to provide accurate information about an impending plant closure] is indistinguishable from an unfair labor practice claim that cou 1990These are the types of claims to which the Garmon preemption doctrine was intended to apply.” (Parker v. Connors Steel Co. (11th Cir. 1988) 855 F.2d 1510, 1516-1517 , rehg. den. (1988) 864 F.2d 795 , cert. den. (1989) 490 U.S. 1066 [ 104 L.Ed.2d 631 , 109 S.Ct. 2066 ]; accord Kolentus v. Avco Corp. (7th Cir. 1986) 798 F.2d 949, 961 , cert. den. (1987) 479 U.S. 1032 [ 93 L.Ed.2d 832 , 107 S.Ct. 878 ] [“The plaintiffs’ common law fraud claim [regarding *1409 failure to provide accurate information about an impending plant closure] is indistinguishable from an unfair labor practice claim that cou | 1 | 1990–1990 |
Kentucky State Police Department v. Equal Employment Opportunity Commission
green
1 sentence1990These are the types of claims to which the Garmon preemption doctrine was intended to apply.” (Parker v. Connors Steel Co. (11th Cir. 1988) 855 F.2d 1510, 1516-1517 , rehg. den. (1988) 864 F.2d 795 , cert. den. (1989) 490 U.S. 1066 [ 104 L.Ed.2d 631 , 109 S.Ct. 2066 ]; accord Kolentus v. Avco Corp. (7th Cir. 1986) 798 F.2d 949, 961 , cert. den. (1987) 479 U.S. 1032 [ 93 L.Ed.2d 832 , 107 S.Ct. 878 ] [“The plaintiffs’ common law fraud claim [regarding *1409 failure to provide accurate information about an impending plant closure] is indistinguishable from an unfair labor practice claim that cou | 1 | 1990–1990 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.