Michael T. Liburdi
How Judge Liburdi rules, drawn from 21 signed orders. Every observation links to the order it came from.
About Judge Liburdi
Michael Thomas Liburdi is a judge of the United States District Court for the District of Arizona. Appointed by President Donald J. Trump, Judge Liburdi received a commission on August 5, 2019.
Judge Liburdi's practices and standing orders
Rules for cases before Judge Liburdi, as published on the court's website (checked October 8, 2026). Judges revise these often, so confirm the current version on the court's site before you file.
Key rules
Motions
In criminal cases, motions in limine are due two weeks before the final pretrial conference, responses one week before it, and no replies are allowed.
“Motions in limine are due two weeks prior to the Final Pretrial Conference. 1 Responses to motions in limine are due one week prior to the final pretrial 2 conference. 3 No replies are permitted.”
Trial
In criminal cases, submit proposed jury instructions and verdict forms in Word to chambers as well as filing them with the clerk.
“IT IS FURTHER ORDERED directing the parties to submit their proposed jury 16 instructions and proposed forms of verdict (in Word) to the chamber’s e-mail address,1 in 17 addition to filing them with the Clerk of the Court.”
Standing orders for every case in this court
Orders the court applies to all of its cases, whichever judge has them, as published on the court's website (checked October 8, 2026).
How Judge Liburdi decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
In State of Arizona v. GlaxoSmithKline LLC, he applied the Grable/Gunn framework and remanded the state consumer-fraud claim because the asserted federal issue was neither necessarily raised nor substantial.
“IT IS THEREFORE ORDERED: (1) The State of Arizona’s motion to remand (Doc. 12) is GRANTED. The Clerk of Court is directed to REMAND this matter to the Arizona Superior Court in Maricopa County.”
In the reviewed wage case, he treated the economic realities as controlling over the parties' lease label and denied both sides summary judgment where half of the employment-status factors remained genuinely disputed.
“There remains a genuine issue of material fact on three factors, and the other three weight in favor of an employment relationship.”
In the reviewed prisoner excessive-force case, he required the summary-judgment movants to identify the record shortfall rather than merely assert that the self-represented plaintiff lacked evidence; the verified complaint itself could function as evidence.
“it is not sufficient simply to assert that the plaintiff has no evidence—Defendants must show it.”
In Aguilera, Liburdi allowed defendants to amend their answer after a deposition clarified evidence about the crash; he found the two-month interval before their motion diligent.
“that moving to amend two months after discovering relevant information is diligent, so 2 the Court finds good cause to amend the Scheduling Order.”
Procedural preferences
In Sun State Towers LLC v. County of Mohave, he granted the county summary judgment on a cell-tower permit dispute because the provider had not shown that its proposed tower was the least intrusive feasible means of filling a coverage gap.
“IT IS ORDERED Defendants’ Motion for Summary Judgment (Doc. 28) is GRANTED.”
In Kelly v. Young, he denied three summary-judgment motions as premature because no responsive pleading or discovery yet permitted assessment of genuine factual disputes.
“Without discovery or a responsive pleading, the Court cannot yet determine whether there is a genuine issue of material fact, so the Court must deny the motions for summary judgment (Docs. 24, 28, 32) as premature.”
In Berent v. City of Surprise, he declined to appoint a guardian ad litem because the record did not show enough evidence of incompetence; he also declined to appoint counsel absent exceptional circumstances.
“The record does not supply enough for the Court to conclude that Ms. Berent is incompetent, so the Court will not appoint a guardian ad litem.”
In Tapestry on Central Condominium Association v. Liberty Insurance Underwriters Incorporated, he denied blanket sealing of a summary-judgment motion and settlement agreement because the insurer gave no specific compelling reason to override public access.
“Liberty has not met its burden to show that compelling reasons justify sealing its Motion for Summary Judgment and the attached Settlement Agreement.”
In a premises-liability case, he left causation for the jury where exposed bolts could reasonably have caused the fall; competing explanations went to credibility rather than summary judgment.
“Circle K’s alternative explanations raise issues of weight and credibility, which are reserved for the jury and not appropriate for resolution at summary judgment.”
In Wells Fargo Bank v. LHS Finance, Liburdi denied intervention for a proposed party seeking to contest potential sanctions allocation because it would introduce collateral disputes about company management.
“Permissive intervention is thus 7 inappropriate because it ‘would only serve to undermine the efficiency of the litigation 8 process.’”
Cautions
In United Association National Pension Fund v. Carvana Company, he dismissed a securities-fraud complaint without prejudice after finding that its puzzle-pleading format failed to identify which statements were false and why, and that it did not plead a strong inference of scienter.
“IT IS ORDERED granting Defendants’ Motion to Dismiss (Doc. 50) and Underwriters’ Joinder (Doc. 52). For the reasons stated above, all Defendants, including Garcia Senior, are dismissed, without prejudice.”
In the reviewed disability-rights case, he denied reconsideration where an intervening decision addressed a different question and the remaining arguments repeated earlier positions or failed to show manifest error.
“With there being no basis for reconsideration, the Court will deny Plaintiffs’ motion (Doc. 79).”
In Speakman, a request for another amendment failed because the asserted due process claim could not be cured by new pleading.
“Plaintiff cannot assert a Due Process claim for a city’s failure to respond to motions to correct an inaccurate police report.”
In Fitzgerald, Liburdi denied a request to reconsider an earlier refusal to stay a habeas case, but separately authorized federal counsel to pursue a specified ineffective-assistance claim in state court.
“IT IS THEREFORE ORDERED that Petitioner’s Motion for Reconsideration 16 (Doc. 115) is DENIED insofar as it seeks reconsideration of this Court’s September 1, 17 2023 Order.”
Signed rulings
A grounded sample of orders signed by this judge, with the verbatim dispositive language.
“IT IS ORDERED granting Defendants’ Motion to Dismiss (Doc. 50) and Underwriters’ Joinder (Doc. 52). For the reasons stated above, all Defendants, including Garcia Senior, are dismissed, without prejudice.”
“IT IS THEREFORE ORDERED that the Motion to Dismiss (Doc. 15) is denied.”
“IT IS THEREFORE ORDERED: (1) The State of Arizona’s motion to remand (Doc. 12) is GRANTED. The Clerk of Court is directed to REMAND this matter to the Arizona Superior Court in Maricopa County.”
“IT IS ORDERED Defendants’ Motion for Summary Judgment (Doc. 28) is GRANTED.”
“IT IS FURTHER ORDERED Plaintiff’s Motion for Summary Judgment (Doc. 30) is DENIED.”
“IT IS ORDERED granting ASmoke's Motion to Dismiss for Lack of Personal Jurisdiction (Part of Doc. 13).”
“IT IS FURTHER ORDERED denying as moot Dansons' Renewed Motion for Preliminary Injunction (Doc. 26).”
“IT IS THEREFORE ORDERED that Plaintiff’s Motion to Retransfer Venue (Doc. 32) is DENIED.”
“Without discovery or a responsive pleading, the Court cannot yet determine whether there is a genuine issue of material fact, so the Court must deny the motions for summary judgment (Docs. 24, 28, 32) as premature.”
“The Court therefore does not have the authority to enter default at this time. And because seeking a default judgment is a two-step process that first requires an entry of default, the Court cannot enter a default judgment. The Court denies Mr. Kelly’s motion for entry of default (Doc. 37) and motion for default judgment (Doc. 39).”
“IT IS FINALLY ORDERED that Plaintiff’s Motion for Service by U.S. Marshals (Doc. 40) is GRANTED IN PART and DENIED IN PART.”
“IT IS FURTHER ORDERED that Plaintiff’s Motions to Appoint Guardian Ad Litem or Pro Bono Counsel (Docs. 2, 24) are DENIED.”
“IT IS FURTHER ORDERED that Plaintiff’s Motion to Reassign Case as Related Case (Doc. 6) is DENIED.”
“The motion will be denied, since Ms. Berent’s complaint (Doc. 1) will be dismissed, and service of any amended complaint will be barred pending the Court’s screening.”
“IT IS FURTHER ORDERED that Plaintiff’s Motion for Order Requiring Defendants to Post Bond to Secure Judgment (Doc. 6) is DENIED.”
“IT IS FURTHER ORDERED that Plaintiff’s Emergency Motion for Writ of Mandamus (Doc. 22) is DENIED.”
“IT IS FURTHER ORDERED that Plaintiff’s Motion for Reconsideration (Doc. 23) is DENIED.”
“IT IS FURTHER ORDERED that Plaintiff’s Motion to Seal (Doc. 28) is DENIED.”
“Defendants’ Motion for Summary Judgment (Doc. 74) is granted as to Plaintiff’s Eighth Amendment claims against Defendants Villanueva and Lopez, and the Motion is denied without prejudice as to Plaintiff’s Eighth Amendment claim against Defendant Tribolet.”
“Plaintiff’s Motion for Temporary Restraining Order (Doc. 112) is denied.”
“Defendants’ Motion to Extend Deadline to Respond (Doc. 114) is denied as moot.”
“IT IS ORDERED granting Defendant Jason McClelland’s Motion for Summary Judgment (Doc. 132).”
“IT IS FURTHER ORDERED granting Defendant Jeffrey Van Winkle’s Motion for Summary Judgment (Doc. 134).”
“IT IS ORDERED Plaintiffs’ Motion for Partial Summary Judgment on Liability (Doc. 222) is DENIED.”
“IT IS FURTHER ORDERED Plaintiffs’ Motion to Strike (Doc. 228) is DENIED.”
“IT IS FURTHER ORDERED Defendants’ Revised Motion for Summary Judgment (Doc. 230) is DENIED.”
“IT IS FINALLY ORDERED Defendants’ Motion to Strike (Doc. 232) is DENIED.”
“IT IS THEREFORE ORDERED denying Plaintiffs’ Motion for Reconsideration of Order on Defendant’s Motion for Summary Judgment (Doc. 79).”
“IT IS FURTHER ORDERED denying Plaintiffs’ Motion for Leave to File a Reply to Defendant’s Response to Motion for Reconsideration (Doc. 83).”
“IT IS ORDERED that Liberty’s Motion for Leave to File Under Seal (Doc. 43) is denied without prejudice.”
Pending matters in the official report
Reported by the Administrative Office of the U.S. Courts under the Civil Justice Reform Act, as of March 31, 2026.
| Motions pending more than six months | 0 |
| Bench trials submitted more than six months | 0 |
| Bankruptcy appeals pending more than six months | 0 |
| Social Security appeals pending more than six months | 0 |
| Civil cases pending more than three years | 8 |
| Report | Motions over six months | Cases over three years |
|---|---|---|
| Mar 2026 | 0 | 8 |
| Sep 2025 | 0 | 7 |
| Mar 2025 | 0 | 6 |
| Sep 2024 | 0 | 6 |
| Mar 2024 | 0 | 3 |
| Sep 2023 | 0 | 8 |
| Mar 2023 | 0 | 8 |
| Sep 2022 | 1 | 5 |
| Mar 2022 | 0 | 5 |
| Sep 2021 | 0 | 3 |
| Mar 2021 | 0 | 1 |
| Sep 2020 | 0 | 0 |
A snapshot on that date: matters listed may since have been decided or reassigned. A motion referred to a magistrate judge is counted for both judges. Motions in multidistrict litigation, section 2255 cases and Social Security appeals are not counted, and a very large three-year count is generally a multidistrict docket. Source: Appendix A of the report (PDF); about the report.
How long civil cases take in this court
For the whole of United States District Court for the District of Arizona, not for Judge Liburdi: median time from filing to disposition of the civil cases the court closed in the 12 months ending September 30, 2025, as reported by the Administrative Office of the U.S. Courts.
| Cases | Median time | |
|---|---|---|
| All civil cases closed | 2,485 | 6 months |
| Closed with no court action | 135 | 2.2 months |
| Closed before pretrial | 2,001 | 5.2 months |
| Closed during or after pretrial | 335 | 15.2 months |
| Closed during trial | 14 | 32.4 months |
| 12 months ending | Cases closed | Median time |
|---|---|---|
| Sep 2025 | 2,485 | 6 months |
| Sep 2024 | 2,278 | 6.7 months |
| Sep 2023 | 2,126 | 8.3 months |
| Sep 2022 | 2,181 | 9.4 months |
| Sep 2021 | 3,857 | 20.9 months |
| Sep 2020 | 8,128 | 12.2 months |
| Sep 2019 | 2,842 | 9.6 months |
The table leaves out prisoner petitions, land condemnations, deportation reviews, recovery of overpayments and enforcement of judgments, and reports no median for fewer than 10 cases. A district that closed a large multidistrict litigation in the period shows very large counts and long medians for that year. Source: Table C-5, U.S. District Courts (spreadsheet).
Draft for Judge Liburdi with the record in hand
Ezel grounds your drafting and research in this profile: what has persuaded Judge Liburdi, and what has not, cited to the signed orders.
Opens in Ezel Pro.
- Grounded in Judge Liburdi's own signed orders
- Cites every source it relies on, so you can verify it
- Chat, drafting and research in one workspace