Jerusha T. Adams
How Judge Adams rules, drawn from 13 signed orders. Every observation links to the order it came from.
How Judge Adams decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
In Social Security review, treats material mischaracterizations of expert testimony and medical records as a failure of substantial-evidence review when those errors drive the disability determination.
“Because the ALJ’s mischaracterizations and inaccuracies concerning Plaintiff’s noncompliance taint the record, the Court concludes the ALJ’s finding that Plaintiff was noncompliant with his treatment is not supported by substantial evidence.”
In a full bench trial on a breach-of-contract and account-stated dispute, she resolved conflicting testimony largely on witness credibility: crediting a witness who 'testified in a thoughtful, candid, and consistent manner' and whose account 'withstood scrutiny on cross examination,' while discounting the opposing witness as 'not credible' because his 'demeanor on the stand was combative and evasive' and he 'contradicted himself multiple times on cross examination.'
“The Court finds Frank Petrusnek to be a credible witness. He testified in a thoughtful, candid, and consistent manner. His testimony withstood scrutiny on cross examination... In comparison, the Court finds Abraham Summers not credible. His demeanor on the stand was combative and evasive. He contradicted himself multiple times on cross examination.”
An unpled affirmative defense is treated as waived even when raised for the first time in post-trial proposed findings: she declined to consider a mitigation-of-damages defense that was not included in the answer.
“This affirmative defense is not included in MIA's answer... Mitigation of damages is an affirmative defense, and failure to plead an affirmative defense results in waiver of that defense.”
Procedural preferences
Screens pro se prisoner and habeas filings for venue quickly and sua sponte: when the facility, the underlying conviction, or the named defendants are outside the Middle District, she transfers, rather than dismisses, the case to the correct district, expressly noting the transfer decides nothing about the merits.
“In light of the foregoing and in accordance with applicable federal law, it is hereby ORDERED that this case is transferred... In transferring this case, the court makes no determination with respect to the merits of the claims pending in this civil action.”
Dismisses redundant official-capacity claims against individual supervisors as a matter of course once the employing agency itself is also a defendant, since a victory against the individual official in that capacity is legally the same as a victory against the agency.
“Official capacity suits are suits against state agencies, not against the people through whom agencies act... a victory against a named individual in an official capacity suit is 'a victory against the entity that employs him.'”
Cautions
A hostile-work-environment or disability-discrimination claim built on conclusory labels, 'completely ostracized,' a supervisor's offensive remarks, will not survive dismissal unless the complaint also alleges facts tying the conduct to the protected characteristic; she has expressly held that offensive language alone, without that factual link, is not enough.
“Plaintiff alleges no facts which support his conclusory allegation that he was completely ostracized. Nor does Plaintiff allege facts that support that this harassment was based on race... It is never appropriate to call someone 'half a person.' Still, under the law of the Eleventh Circuit, Plaintiff's allegations are not enough to survive the Department's motion to dismiss.”
Signed rulings
A grounded sample of orders signed by this judge, with the verbatim dispositive language.
“the undersigned finds that the Plaintiff's Motion to Proceed in Forma Pauperis (Doc. No. 2) is due to be GRANTED”
“it is the RECOMMENDATION of the Magistrate Judge that this case be TRANSFERRED to the United States District Court for the Northern District of Alabama under 28 U.S.C. § 2241(d).”
“the undersigned Magistrate Judge RECOMMENDS that this case be TRANSFERRED to the United States District Court for the Northern District of Alabama under 28 U.S.C. § 2241(d).”
A sua sponte order transferring a pro se prisoner's Section 1983 medical-care claim to the Northern District of Alabama under 28 U.S.C. Section 1406(a) once the case narrowed to a correctional facility located in that district; this venue determination did not rule on a party motion. 'ORDERED that this case is transferred to the United States District Court for the Northern District of Alabama pursuant to the provisions of 28 U.S.C. Section 1406(a). In transferring this case, the court makes no determination with respect to the merits of the claims pending in this civil action.'
A sua sponte recommendation transferring a pro se prisoner's Section 1983 claim against a state court, prosecutor, and defense counsel to the Southern District of Alabama under 28 U.S.C. Section 1406, the district where the underlying state criminal proceeding and the individual defendants were located; this venue determination did not rule on a party motion. 'it is the RECOMMENDATION of the Magistrate Judge that this case be transferred to the United States District Court for the Southern District of Alabama in accordance with the provisions of 28 U.S.C. Section 1406(a).'
A sua sponte recommendation transferring a pro se prisoner's Section 1983 claim against a county sheriff, a state circuit judge, and a prosecutor to the Northern District of Alabama, the district where the underlying incident and all named defendants were located; this venue determination did not rule on a party motion. 'the undersigned RECOMMENDS that this case be TRANSFERRED to the United States District Court for the Northern District of Alabama under 28 U.S.C. Section 1391(b) and 28 U.S.C. Section 1404(a).'
A sua sponte recommendation transferring a pro se prisoner's Section 1983 COVID-19 prison-conditions claim to the Southern District of Alabama under 28 U.S.C. Section 1404(a), the district where the correctional facility and the individually responsible officials were located; this venue determination did not rule on a party motion. 'it is the RECOMMENDATION of the Magistrate Judge that this case be transferred to the United States District Court for the Southern District of Alabama in accordance with the provisions of 28 U.S.C. Section 1404(a).'
“The Commissioner's unopposed motion (Doc. No. 15 ) is GRANTED. 2. The decision of the Commissioner is hereby REVERSED. 3. This matter is hereby REMANDED to the Commissioner for further proceedings pursuant to sentence four of 42 U.S.C. § 405(g).”
“The Commissioner's unopposed motion (Doc. No. 21 ) is GRANTED. The decision of the Commissioner is hereby REVERSED. This matter is hereby REMANDED to the Commissioner for further proceedings pursuant to sentence four of 42 U.S.C. § 405(g).”
“Plaintiff’s motion for summary judgment (Doc. No. 15) is GRANTED. The Commissioner’s motion for summary judgment (Doc. No. 18) is DENIED. This action is REVERSED and REMANDED to the Commissioner pursuant to sentence four of 42 U.S.C. § 405(g) for further proceedings consistent with this Memorandum Opinion and Order.”
“The Commissioner’s unopposed motion (Doc. No. 21) is GRANTED. The decision of the Commissioner is hereby REVERSED. This matter is hereby REMANDED to the Commissioner for further proceedings pursuant to sentence four of 42 U.S.C. § 405(g).”
“Plaintiff's motion for summary judgment (Doc. No. 11) is GRANTED. The Commissioner's motion for summary judgment (Doc. No. 21) is DENIED. The Commissioner's decision is REVERSED. This matter is REMANDED for further proceedings pursuant to sentence four of 42 U.S.C. § 405(g).”
Caseload & timing
From public federal docket records for this judge.
Her sampled consent-jurisdiction caseload spans Social Security disability appeals (the largest single category), Title VII/Section 1981 employment discrimination, a prisoner Eighth Amendment medical-care suit, a municipal excessive-force case, a commercial breach-of-contract dispute resolved by a full bench trial, and a Federal Tort Claims Act case: consistent with a general consent civil docket with a strong Social Security component, typical of this court's magistrate judges.
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