Julie G. Rikelman

U.S. Court of Appeals for the First Circuit circuit Appointed by Joe Biden (Democratic) 26 signed orders read

How Judge Rikelman decides

Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.

What persuades

In assessing whether persecution was motivated by a protected trait, she gives the greatest weight to what the persecutors themselves said during the attack, not just the surrounding circumstances.

“The attackers' own statements show that, regardless of whatever else prompted the beating, Khalil would not have been harmed had he agreed to convert.”

She scrutinizes whether a lower court's factual finding actually engaged with the undisputed record, not just its bottom-line label -- a general finding of 'adequate care' cannot survive when the specific, undisputed treatment records contradict it.

“We conclude that the district court overlooked the undisputed evidence demonstrating that, almost one year after Burgos's sleep apnea diagnosis and despite his ongoing severe hypertension, the BOP had yet to provide Burgos with the established treatment for sleep apnea.”

When a very recent panel decision squarely controls the legal question presented, she applies it directly rather than re-litigating the underlying policy debate from scratch.

“Our recent decision in Rosa v. Bondi ... resolves this appeal and requires us to rule in favor of the Borges family.”

Procedural preferences

She reads the Ex parte Young sovereign-immunity exception narrowly: a claim styled as forward-looking relief must actually target an ongoing violation of federal law, not repackage a past wrong.

“Plaintiffs' attempt to recover their forfeited property focuses on a past alleged wrong, but the Ex parte Young exception applies only when individuals seek prospective relief against a state official's ongoing violation of federal law.”

She treats Rule 11's safe-harbor timing as mandatory, not a mere formality -- a movant who serves its sanctions motion only after the district court has already ruled has forfeited the remedy entirely, regardless of the underlying merits.

“a party seeking sanctions must follow a two-step process ... [it] must serve the Rule 11 motion on the opposing party at least twenty-one days before filing the motion with the district court, and sanctions may be sought only if the challenged pleading is not withdrawn or corrected within twenty-one days after service of the motion.”

She resolves statutory-scope disputes by testing a party's proposed narrowing against the statute's plain text, rather than deferring to either side's characterization of what the statute was meant to cover.

“We conclude that Section 1659's scope is not as narrow as Vicor claims and that the statute's plain text required the district court to grant Foxconn's stay request.”

Cautions

A stay or appellate applicant who argues around the specific order actually under review, rather than meeting it head-on, loses regardless of how strong its arguments are on adjacent issues.

“In its stay papers, the government largely ignores the enforcement order ... it devotes, at most, three sentences to addressing that order.”

Defendants cannot invoke the Heck v. Humphrey bar to block a related civil rights suit when the plaintiff's criminal case ended in a pretrial-probation dismissal with no guilty plea or admission of wrongdoing -- there is no valid criminal judgment for the civil verdict to impugn.

“the Heck bar is not triggered when there is no underlying criminal conviction or sentence”

Identifying one, non-protected motive for a petitioner's mistreatment does not by itself rule out a protected ground -- the agency must actually grapple with whether both motives coexisted, not stop the analysis at the first motive it finds.

“the agency cannot conclude that there are no mixed motives simply by identifying one motive.”

Signed rulings

A grounded sample of orders signed by this judge, with the verbatim dispositive language.

Lilian Eugenia Varela-Chavarria v. Merrick B. Garland, Attorney General
22-1780 · 2023-11-09
Petition for review (petitioner) Denied

“Accordingly, we deny the petition.”

Nicholas L. Triantos v. Guaetta & Benson, LLC, et al.
21-1774 · 2024-01-30
Appeal (appellant) Granted

“Because the court imposed sanctions under Rule 11 without following the rule's procedural requirements, we reverse and vacate the order.”

United States v. Randall Crater
23-1159 · 2024-02-23
Appeal (appellant) Denied

“Because Crater's arguments cannot be squared with controlling precedent or the record in this case, we affirm.”

United States v. Andy G. Morales-Velez
21-1264 · 2024-05-03
Appeal (appellant) Denied

“After careful consideration, we affirm Morales's sentence.”

Appeal (appellant) Moot / procedural

“because Morales has reached a settlement with the government over the seized $20,000, we conclude that his claims regarding the Rule 41(g) motion are moot.”

Sandra Natasha St. John v. Andrea Joy Campbell
25-1354 · 2026-04-29
Appeal (appellant) Denied

“Because St. John was not in the custody of any Massachusetts state official when she filed her petition, we affirm.”

Rosa Lidia Cante Mijangos v. Pamela J. Bondi, Attorney General
25-1267 · 2026-02-18
Petition for review (petitioner) Denied

“we must deny the petition because she has failed to develop any challenge to the legal and factual bases for the BIA's ruling.”

Sine Phimmady v. Pamela Bondi, Attorney General
24-1330 · 2025-02-10
Petition for review (petitioner) Denied

“Because we conclude the BIA does not have the settled practice that Phimmady describes, we deny his petition.”

Miya Water Projects Netherlands B.V. v. Financial Oversight and Management Board for Puerto Rico
24-1286 · 2025-05-19
Appeal (appellant) Denied

“We agree with the district court that Puerto Rico's Eleventh Amendment immunity extends to the Board and that the Commonwealth did not waive that immunity through TEPPRA. Thus, we affirm.”

United States v. Hector Maldonado-Maldonado
22-1650 · 2025-04-11
Appeal (appellant) Granted

“We agree with the parties that, even under the plain error standard that applies here, Maldonado has established that he is entitled to resentencing because of the government's breach.”

Neyza Cruz-Cedeno, et al. v. Fernando Vega-Moral
23-1609 · 2025-08-08
Appeal (appellant) Denied

“We agree with the district court's analysis and thus affirm.”

Vicor Corporation v. FII USA Inc., et al.
24-1620 · 2025-03-06
Appeal (appellant) Granted

“Thus, we vacate the order granting the preliminary injunction and remand to the district court for further proceedings.”

George Rodrique, II v. Hearst Communications, Inc., et al.
24-1289 · 2025-01-17
Appeal (appellant) Denied

“Thus, we affirm the district court's order granting summary judgment to Hearst, albeit on different grounds.”

Put Judge Rikelman's record to work

Ezel drafts and answers grounded in this exact profile: how Judge Rikelman actually rules, not a generic AI guess.

Opens in Ezel Pro. Every answer is grounded in Judge Rikelman's own signed orders and cites them.