A. Marvin Quattlebaum Jr.
How Judge Quattlebaum rules, drawn from 52 signed orders. Every observation links to the order it came from.
How Judge Quattlebaum decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
At summary judgment, a concrete chain of circumstantial evidence can create a triable causation issue even when no witness saw the precise mechanism of injury; photographs, physical marks, witness accounts, and a supported expert opinion may collectively move the claim beyond speculation.
“We make no comment on which parties’ evidence is more persuasive. We only ask whether Sedar has provided ‘evidence beyond speculation that provides a sufficient basis for a reasonable inference of causation.’”
Circumstantial evidence can preserve a jury question when its timing, an abrupt departure from prior conduct, and the scale of the conduct together support the requested inference; judgment as a matter of law is not an occasion to decide which inference is ultimately true.
“But our job in reviewing an order granting a motion for judgment as a matter of law is not to decide whether Wright in fact possessed inside information before December 9; it is to decide whether there was evidence from which a reasonable jury could have concluded that he had such information. And there was.”
In a credit-reporting case, Quattlebaum rejected a categorical divide between legal and factual disputes. Either can support a reinvestigation claim when the alleged inaccuracy is objective, readily verifiable, and pleaded with facts showing the report was actually inaccurate or incomplete.
“both legal and factual disputes can form the basis of a § 1681s-2(b) claim, so long as they are objectively and readily verifiable.”
At dismissal, Quattlebaum allowed consideration of an integral, authentic recording only when it plainly contradicted the complaint's factual version. A recording may cast doubt on an allegation without making that allegation implausible as a matter of law.
“this exception is narrow. It only allows a court to rely on a recording to dismiss a complaint under Rule 12(b)(6) when the recording blatantly contradicts ‘the plaintiff’s version of the facts.’”
Procedural preferences
He applies the fraudulent-joinder standard as more demanding than ordinary pleading review. When state law is unsettled and a claim remains possible, doubts about removal belong in state court rather than in an early federal merits determination.
“At this stage, a district court shouldn’t wrestle with thorny state-law questions, nor should it otherwise ‘delv[e] too far into the merits.’”
In multidistrict litigation, Quattlebaum recognized broad docket-management authority but would not let a lead-counsel consent requirement prevent a party from filing a statutory arbitration-stay motion. Scheduling can control timing without eliminating a substantive right to seek the stay.
“the fact that a proceeding occurred in a[n] MDL setting does not alter the substantive rights of the litigants.”
Cautions
A discrimination complaint needs factual detail connecting the challenged treatment to race, including concrete comparator allegations where the theory depends on differential treatment; repeating causation elements and asserting a double standard do not make the claim plausible.
“Without factual detail, we are unable to infer that WakeMed intended to interfere with a contractual interest of Nadendla on the basis of race.”
Expert evidence should explain specialized industry practice rather than tell the court what a contract means. An opinion built on contract interpretation risks exclusion as a legal conclusion even in a technically specialized field.
“But Cass is testifying to this contract’s meaning, rather than practices in the industry.”
Quattlebaum required class proponents to present evidentiary proof of an actual damages methodology tied to their theory of liability. Describing a general method or promising to solve predominance later was insufficient at certification.
“Rule 23 ‘does not set forth a mere pleading standard.’ It requires evidence.”
In a juror-nondisclosure case, Quattlebaum required more than dishonesty during voir dire; the movant also had to show that truthful disclosure would have required striking the juror for cause. Appellate review deferred to the trial court's supported impartiality finding.
“The Juror may have been dishonest during voir dire. And his role in the affairs of Team Mingo is indeed disturbing. But under our standard of review, we defer to the district court’s determination that the Juror was impartial”
Signed rulings
A grounded sample of orders signed by this judge, with the verbatim dispositive language.
“REVERSED, VACATED AND REMANDED WITH INSTRUCTIONS”
“AFFIRMED AS MODIFIED”
“PETITION FOR REVIEW GRANTED; VACATED AND REMANDED”
“For the reasons stated above, the district court’s decision that Zurich did not abuse its discretion in denying Geiger’s application for LTD benefits is AFFIRMED.”
“For the reasons above, we vacate Mathis’ sentence and remand for proceedings consistent with this opinion.”
“For the foregoing reasons, the district court’s dismissal of Alberti’s complaint is AFFIRMED.”
“AFFIRMED IN PART, VACATED IN PART AND REMANDED”
“Therefore, the district court did not err in dismissing the members’ amended complaint. AFFIRMED”
“For the reasons described above, we vacate and remand to the district court with the following instructions ... VACATED AND REMANDED”
“For the foregoing reasons, we reverse the district court’s order granting summary judgment to the Union and denying summary judgment to AVSW. As a result, we vacate the underlying arbitration award. REVERSED”
“the district court’s ultimate judgment directing Zayo to pay the rent determined by the appraisers is AFFIRMED.”
“For the foregoing reasons, we conclude that Delafield was afforded adequate due process and we affirm the district court’s order. AFFIRMED”
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