Carl Edmond Stewart
How Judge Stewart rules, drawn from 37 signed orders. Every observation links to the order it came from.
How Judge Stewart decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
In reviewing a jury-selection challenge, Stewart emphasized that the trial court must evaluate the prosecutor's stated reason at the time of the strike. Additional facts elicited by the court cannot substitute for testing whether the prosecutor's own explanation was genuine or pretextual.
“the Batson framework . . . requires a focus on the actual, contemporary reasons articulated for the prosecutor's decision to strike a prospective juror.”
In a maritime limitation action, Stewart evaluated notice by considering all the information received by the vessel owner, including the claimed categories of damages and medical evidence. The six-month filing period did not depend on a particular settlement demand once the materials showed a reasonable possibility that the claim exceeded the vessel's value.
“In this case, the district court considered the totality of the evidence in deciding that Genesis should have known before June 13, 2024 that there was a reasonable possibility that Darrow's claim could exceed $12.5 million.”
In a trademark case, Stewart assessed actual-confusion evidence against the scale and duration of the parties' sales. Five instances over roughly two and a half years could not sustain that factor where annual sales reached millions of dollars.
“This evidence is ultimately insufficient to sustain a finding of a likelihood of confusion given the fact that the parties' sales ran into the millions of dollars each year.”
Procedural preferences
In a civil-rights action arising from municipal prosecutions, Stewart treated the state-law trial-de-novo request as eliminating the finality of the municipal judgments. With the prosecutions still pending, the federal claims were not yet barred by a final conviction.
“In sum, because Kleinman's and AusPro's prosecutions are ongoing, there is no final conviction, and Heck cannot yet apply.”
Cautions
In an appeal from receivership orders, Stewart enforced the appellant's burden to establish appellate jurisdiction. Implying that an earlier precedential decision was factually different did not suffice when the appellant failed to identify the distinctions.
“But Barton fails to meet his burden of showing that we have appellate jurisdiction.”
Signed rulings
A grounded sample of orders signed by this judge, with the verbatim dispositive language.
“In light of recent Supreme Court precedent illuminating the standard for ‘exceptional’ cases which warrant the award of attorney's fees, we REVERSE and REMAND.”
“Charles now appeals Charles II. We dismiss for lack of appellate jurisdiction.”
“Mr. Gonzalez-Longoria has been released from imprisonment and no longer wishes to pursue any challenge to his term of imprisonment or Sentencing Guideline calculation. Accordingly, we DISMISS his appeal as to these issues. ... We REMAND to the district court for the limited purpose of correcting the judgment to reflect the correct offense of conviction ...”
“We agree with Vega-Santos that this condition impermissibly delegates the district court's sentencing authority. Accordingly, we VACATE the condition and REMAND for resentencing.”
“For the foregoing reasons, the sentence of Defendant-Appellant Jose Ricardo Flores is AFFIRMED.”
“We AFFIRM the district court’s judgment but reform it to correct a clerical error in the statute of conviction.”
“Because the BIA erred in construing 8 U.S.C. § 1227(a)(2)(A)(iii) to apply to an individual who was a naturalized citizen at the time of conviction, we grant the petition for review and vacate the BIA’s deportation order.”
“Accordingly, Cabrera’s petition for review is DENIED, in part, and GRANTED, in part, and the case is REMANDED for further proceedings not inconsistent with this opinion.”
Caseload & timing
From public federal docket records for this judge.
Circuit judges do not manage an assigned federal trial docket in their appellate role. Stewart previously served on Louisiana trial and appellate courts.
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