Thomas Lee Ambro
How Judge Ambro rules, drawn from 42 signed orders. Every observation links to the order it came from.
About Judge Ambro
Thomas L. Ambro is a judge of the United States Court of Appeals for the Third Circuit. Appointed by President William J. Clinton, Judge Ambro received a commission on February 16, 2000. Judge Ambro assumed senior status on February 6, 2023.
Judge Ambro's practices and standing orders
The court's website lists no individual practices or standing orders of Judge Ambro's own (checked October 11, 2026), so the court's local rules and general orders are the place to look (court page ↗).
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 11, 2026).
- Third Circuit Motions Practice ↗
- Motions to Exceed the Page or Word Limitations ↗
- Motions for Extensions of Time and Clarification of L.A.R. 110 ↗
- Vacating Option B for Filing of an Appendix ↗
- Reduced Number of Copies of Briefs Required ↗
- Stays in Immigration Cases ↗
- Submission of Audio and Video Files ↗
How Judge Ambro decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
In In re Genesis Health Ventures, he construed the undefined term 'disbursement' in the quarterly bankruptcy-fee provision to include operating expenses paid through an affiliate's centralized cash system on each debtor's behalf.
“Thus we interpret the word in accordance with its 'ordinary, contemporary, common meaning.'”
In In re Energy Future Holdings, he held that the debtors owed make-whole premiums on optional redemptions of their notes despite acceleration, because the indentures' redemption provisions remained operative.
“It surpasses strange to hold that silence in section 6.02 supersedes section 3.07's simple script.”
Procedural preferences
In the Tribune Media bankruptcy appeal, he described equitable mootness as a narrow basis for declining review of a consummated reorganization plan and explained that a court should consider practicable relief before dismissing an appeal.
“when a court applies the doctrine of equitable mootness, it does so with a scalpel rather than an axe.”
In Marcus v. BMW of North America, he vacated certification of a class concerning allegedly defective run-flat tires because identifying class members and resolving their claims required individualized inquiries.
“If class members are impossible to identify without extensive and individualized fact-finding or 'mini-trials,' then a class action is inappropriate.”
In Fields v. City of Philadelphia, he addressed the First Amendment right to record police performing public duties before considering qualified immunity, and reversed summary judgment on the constitutional issue.
“We reject this invitation to take the easy way out.”
In United States v. Birry, Ambro held that a reasonable person would understand the officer-suspect exchange to authorize a search beyond Birry’s pockets, and affirmed denial of his suppression motion.
“Viewing the facts in the light most favorable to the Government, as we must in this posture, we conclude that a ‘typical reasonable person [would] have understood by the exchange between the officer and the suspect’ that the request to search was not limited to Birry’s pockets.”
In United States v. Tavares, Ambro's opinion held that a negotiated proffer waiver covering evidence and arguments offered for the defendant also reached a defense opening statement. The statement advanced a factual theory contradicting the defendant's proffer admissions, and the panel affirmed the judgment.
“A proffer waiver reaching evidence or arguments offered on a defendant’s behalf at trial extends to an opening statement that affirmatively advances a factual theory contradicting admissions at the proffer session.”
In United States v. Strickland, Ambro affirmed the jury instructions because the omitted sentence of Model Instruction 4.12 misstated the law on chain of custody.
“Because the final sentence of Model Instruction 4.12 is not legally correct, the District Court did not abuse its discretion by omitting it from the jury instructions.”
Cautions
In Chavez-Alvarez v. Attorney General, Ambro held that the BIA could not treat a military sentencing factor as a separate criminal offense for removal purposes because only Congress can define federal crimes.
“The takeaway is that the Executive Branch, whether through the President or one of its agencies, cannot create criminal statutes; only Congress can do so.”
In Rosenberg v. DVI Receivables, he held that Bankruptcy Code § 303(i) did not preempt state-law damage claims by nondebtors arising from an involuntary bankruptcy filing, absent evidence that Congress intended an exclusive remedy.
“Absent evidence that Congress actually meant for section 303(i) to be an exclusive remedy, we do not make the same inference.”
Signed rulings
A grounded sample of orders signed by this judge, with the verbatim dispositive language.
“Thus we affirm in part and vacate and remand in part to the Bankruptcy Court.”
“Accordingly, we reverse the decision of the District Court and remand for further proceedings.”
“The judgments of the District Court are reversed with instructions to remand to the Bankruptcy Court for further proceedings consistent with this opinion.”
“We thus reverse and stay only the part of the Sale Order that allows Revel to sell the Casino free and clear of IDEA'S lease.”
“we affirm the sentence imposed.”
“We thus reverse and remand for further proceedings.”
“Thus we affirm.”
“We thus vacate the District Court's certification order and remand for proceedings consistent with this opinion.”
“Here we conclude that the District Court did not select the proper standard of review, and so we vacate and remand for consideration under the standard we deem to apply. We affirm, however, the Court's grant of summary judgment on Post's claim for breach of fiduciary duty because it is barred by res judicata.”
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