William J. Kayatta Jr.

How Judge Kayatta rules, drawn from 52 signed orders. Every observation links to the order it came from.

Court
U.S. Court of Appeals for the First Circuit
Position
circuit
Appointed by
Barack Obama (Democratic)
Commissioned
2013-02-14
Education
Amherst College (B.A., 1976); Harvard Law School (J.D., magna cum laude, 1979)
Signed orders read
52

How Judge Kayatta decides

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

What persuades

For disability-discrimination and leave-retaliation claims, he requires evidence that the person responsible for the challenged action knew of the protected condition or planned leave.

“The lack of such knowledge precludes any claim of disability discrimination or of FMLA retaliation due to her planned 2016 leave.”

He reads a choice-of-law clause according to its precise scope and will not extend language governing contract construction to statutory rights the clause does not mention.

“It does not otherwise select any state's law as governing the parties' rights and obligations that are created by statute.”

At sentencing, he requires an explanation that permits meaningful review when the court rejects a substantial, preserved mitigation argument.

“As a result, we conclude that the district court abused its discretion and committed procedural error by failing to explain at all whether and why it rejected Flores-Nater's argument concerning his age at the time of the offense.”

Procedural preferences

He favors adjudication on the merits and treats dismissal with prejudice for an isolated lapse as inappropriate when a lesser sanction would address the harm.

“Faced with an innocent and undisputed reason for counsel's absence, the district court should have concluded that while some sanction might have been appropriate, dismissal with prejudice was too harsh given the circumstances.”

When an indictment adequately states an offense, he does not use a disputed Rule 12 record to test the sufficiency of the government's eventual trial evidence.

“That ruling presumes that a Rule 12(b) motion provides an occasion to force the government to defend the sufficiency of its evidence to be marshalled in support of proving the charged offense. It does not.”

Signed rulings

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

United States v. Zapata-Vazquez
13-2170 · 2015-02-02
Appeal (appellant (defendant Giovanny Zapata-Vazquez)) Denied

“Finding no error, we affirm.”

Hoover v. Harrington (In re Hoover)
15-2383 · 2016-07-05
Appeal (appellant (debtor John E. Hoover, III)) Denied

“The judgment of the district court, affirming the order of the bankruptcy court, is affirmed.”

Holder v. Sessions
15-1864 · 2017-02-17
Petition for review (petitioner (Keith Desmond Holder)) Denied

“Finding no proper basis upon which to disregard the force and logic of our holdings in Lawrence and Cruz-Bucheli, we dismiss Holder's petition for review.”

Camerano v. United States
16-2025 · 2017-04-19
Appeal (appellant (plaintiff Peter Camerano, estate representative)) Denied

“For the foregoing reasons, we affirm.”

McKeague v. One World Technologies, Inc.
16-2148 · 2017-06-08
Appeal (appellant (plaintiff Todd McKeague)) Denied

“The district court acted well within its discretion in dismissing the instant case ... Affirmed.”

United States v. Dent
16-2005 · 2017-08-08
Appeal (appellant (defendant Christian Dent)) Denied

“For the foregoing reasons, we affirm the district court's denial of Dent's motion to suppress.”

Insurance Brokers West, Inc. v. Liquid Outcome, LLC
17-1372 · 2017-10-23
Appeal (appellant (plaintiff Insurance Brokers West, Inc.)) Denied

“We therefore affirm the dismissal of IBW's complaint for failure to meet the amount-in-controversy requirement for diversity jurisdiction under 28 U.S.C. 1332.”

Keane v. HSBC Bank USA, N.A.
16-1045 · 2017-10-31
Appeal (appellant (plaintiff John A. Keane)) Granted

“The district court's denial of Keane's motion to vacate the prior order dismissing his case is reversed, the order dismissing the case is vacated, and the case is remanded to the district court for further proceedings consistent with this opinion.”

United States v. Marte-De La Cruz
16-2152 · 2017-12-04
Appeal (appellant (defendant Santos Marte-De La Cruz)) Moot / procedural

“Because Marte-de la Cruz waived his right to appeal as part of his plea agreement, we dismiss his appeal.”

United States v. Payne
17-1382 · 2018-01-31
Appeal (appellant (defendant Leon Payne)) Denied

“Accordingly, finding no clear error, we affirm the district court.”

United States v. Rosado-Cancel
17-2195 · 2019-03-05
Appeal (appellant (defendant William Rosado-Cancel)) Denied

“Finding no error, we affirm the judgment of the district court.”

United States v. Rodriguez-Rivera
17-1975 · 2019-03-11
Appeal (appellant (United States)) Granted

“Because we agree with the latter argument, we need not consider the former, and we reverse the order of dismissal.”

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