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Decision levers
AI-measured from their own opinions — each lever cites its cases
PurposivismTextualism
Opinions parse statutory definitions and procedural rules literally, as in the broad application of conviction definitions under the Social Security Act and timeliness provisions under civil rules. Proa v. NRT Mid Atlantic, Inc. ↗ Rudman v. Leavitt ↗
Willing to revisit precedentStrong stare decisis
Opinions apply established tests such as Strickland for ineffective assistance and the integral-and-indispensable standard for FLSA claims without questioning their validity. Merzbacher v. Shearin ↗ Perez v. Mountaire Farms, Inc. ↗
Deference to government powerSkepticism of government power
The court upheld a mandatory five-year exclusion by the Secretary of Health and Human Services based on a conviction record while scrutinizing state post-conviction factual findings in a habeas petition. Merzbacher v. Shearin ↗ Rudman v. Leavitt ↗
The case concerns a federal habeas corpus petition under 28 U.S.C. § 2254 filed by John Joseph Merzbacher, who was convicted in state court of child rape and related offenses and sentenced to multiple life terms. Merzbacher alleged ineffective assistance of counsel because his two trial attorneys failed to inform him of or fully discuss a pretrial plea offer under which the state would recommend and a judge would impose a ten-year sentence. The state post-conviction court denied relief after an evidentiary hearing, relying on one deceased attorney's reputation for dishonesty to discredit her testimony that she had not conveyed the offer and instead finding that Merzbacher had been fully advised and rejected it. The federal district court held that these state-court factual findings were unreasonable in light of the record evidence and that Merzbacher had shown deficient performance and prejudice under Strickland v. Washington, and therefore granted the writ ordering the state to restore the status quo ante so Merzbacher could decide whether to accept the original offer, contingent on a judge's willingness to impose the ten-year sentence.
This case involves a declaratory judgment action by National Union Fire Insurance Co. against its insured, Porter Hayden Co., seeking a ruling that it owes no defense or indemnity obligations under four comprehensive general liability policies for asbestos-related bodily injury claims. Porter Hayden had filed for Chapter 11 bankruptcy, and its confirmed reorganization plan created an Asbestos Bodily Injury Trust to process and pay such claims in place of direct lawsuits against the company. The court granted Porter Hayden's motion for partial summary judgment and denied National Union's cross-motion, holding that the policies' coverage for bodily injury caused by occurrences during the policy periods extends to costs of handling claims submitted to the Trust. The reasoning centered on the policy language obligating the insurer to defend suits seeking damages for covered injuries, the explicit provision that bankruptcy does not relieve the insurer of its obligations, and the conclusion that the insurer's refusal to participate waived any bar from the policies' no-action clauses.
This case involved three real estate agents who brought claims including racial and religious discrimination against their employer. The court had previously granted summary judgment to defendants on all federal claims. The pending motion sought reconsideration of an order that had overruled plaintiffs' objections to two magistrate judge awards of attorney fees and costs to defendants arising from discovery disputes. The court granted the motion in part, ruling that the objections were timely under Rules 72(a), 6(d), and 5(b)(2)(E) due to electronic service, but otherwise denied it, adopting the magistrate judge's findings that plaintiffs lacked substantial justification for their discovery positions and that the fee awards were reasonable.
In Proa v. NRT Mid Atlantic, Inc., three licensed real estate agents affiliated with a Maryland brokerage sued the brokerage companies, a former branch manager, and a regional vice president, alleging racial and religious discrimination that caused them pecuniary and non-pecuniary harms, along with related state-law claims. The plaintiffs asserted they were employees rather than independent contractors and claimed the branch manager systematically undermined non-Caucasian and non-Christian agents while the supervisor tolerated the conduct. After discovery, the court granted the defendants' renewed motions for summary judgment on the federal claims under Title VII and 42 U.S.C. § 1981, finding that the plaintiffs could not establish prima facie cases of discrimination or retaliation due to insufficient evidence of protected activity, adverse actions, or pretext. The court declined to exercise supplemental jurisdiction over the remaining state-law breach-of-contract claims and dismissed them without prejudice. The opinion notes that the contractual arrangements treated the agents as independent contractors and that Maryland regulations required certain supervisory oversight by the brokerage.
This case involved a consolidated patent infringement action in which Leviton Manufacturing Co. sued for infringement of its U.S. Patent No. 6,864,766 covering a ground fault circuit interrupter, while Shanghai Meihao Electric sought a declaratory judgment of non-infringement, invalidity, or unenforceability. After contentious discovery, Leviton moved to dismiss its claims voluntarily with prejudice, which the court granted while preserving Meihao's ability to seek fees and costs. The district court adopted the magistrate judge's report and recommendation, overruled Leviton's objections, and awarded Meihao $726,579.15 in attorneys' fees plus $84,080.20 in costs under 35 U.S.C. § 285. The core reasoning was that Meihao was the prevailing party due to the with-prejudice dismissal, the case qualified as exceptional because of Leviton's inequitable conduct before the PTO and vexatious litigation tactics, and fees were necessary to avoid gross injustice.
This case is an employment discrimination lawsuit filed in 2005 by real estate agents against their employer. Plaintiffs moved to vacate the appointment of Magistrate Judge Gauvey to handle discovery and to set aside her discovery rulings, arguing that the referral process was improper because it was reassigned by the clerk's office rather than directly by the district judge, and that her additional role in conducting mediation created an appearance of bias. The court denied the motion, ruling that district judges may make general referrals to magistrate judges that are then randomly assigned, making any reassignment a curable procedural matter rather than a jurisdictional defect. The court further held that a magistrate judge's dual role in managing discovery and facilitating settlement does not violate legal standards or create disqualifying bias, particularly where no prejudice was shown and objections were raised only after unfavorable rulings.
