Chad Andrew Readler
How Judge Readler rules, drawn from 50 signed orders. Every observation links to the order it came from.
How Judge Readler decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
Reaches for dictionaries and ordinary-usage evidence over specialized legal gloss when interpreting undefined contract/policy terms: an ERISA 'crime' exclusion was read to mean whatever an ordinary speaker would call a crime, not a term of art requiring intent-to-cause-death.
“the plain and ordinary meaning of crime includes reckless driving.”
Readler applied the tax statute's numerical safe-harbor test without adding a qualitative inquiry not found in its text.
“We agree with Fitzgerald that § 4052(f)(1) poses a bright-line, 75% test without any further qualitative inquiry, meaning its vehicles constructed with used engines and transmissions could qualify for the safe harbor.”
Readler treated a facially discriminatory state energy rule as subject to strict scrutiny regardless of whether the state's asserted purpose was benign.
“Even the most benign purpose, for instance, cannot save a facially discriminatory law from strict scrutiny.”
For protection against private threats under the Convention Against Torture, Readler required evidence that a public official would acquiesce in the threatened conduct.
“Because the Patels’ CAT claims are based on local officials ignoring threats from a nongovernmental entity (i.e., the loan sharks), they must show that a public official would acquiesce to the loan sharks’ conduct.”
Procedural preferences
Enforces procedural default and forfeiture rigorously and will raise a procedural bar sua sponte to deny relief even when the government/warden itself forfeited the argument below: preservation rules bind litigants on both sides equally.
“Whitman procedurally defaulted his federal due process claim.”
Readler required a habeas petitioner seeking remand over an incomplete record to identify a specific factual inaccuracy or evidentiary gap, not merely dispute the state court's interpretation.
“To trigger remand under this exception, a petitioner must do more than challenge how the state court interpreted the facts or drew inferences.”
Cautions
His qualified-immunity dissents turn on his reading of circuit precedent and the specific facts rather than a consistent alignment with either side. He has dissented at length from majority opinions granting relief to prisoners or citizens when he concluded existing precedent compelled the opposite result.
“Contrary to the majority opinion, I would affirm the district court.”
Reviewing denial of an immigration motion to reopen, Readler asked whether the agency had engaged the central theory and supplied a rational explanation rather than whether the court preferred a different result.
“In the end, we cannot say the Board’s decision was so irrational as to warrant a remand.”
Signed rulings
A grounded sample of orders signed by this judge, with the verbatim dispositive language.
“Finding no error in the district court's Fourth Amendment or sentencing analyses, we AFFIRM the decision below.”
“But resolution of those issues must remain on ice, so to speak, because they were not preserved for appellate review. On that basis, we affirm the judgment of the district court.”
“As substantial evidence supports that determination, we affirm. In so doing, we reject Moats's argument that the ALJ failed to adequately develop the record.”
Authored separate writing (NOT a panel disposition; excluded from the appellate-disposition counts). Cole, J. (joined by Stranch) authored the majority; Readler concurred in part and in the judgment. Subject: a 42 U.S.C. 1983 claim by a juvenile detainee (J.H.) held in a single cell at a county juvenile detention center, and the Bell v. Wolfish framework for pretrial-detainee 'punishment.' Grounding quote: 'CHAD A. READLER, Circuit Judge, concurring in part, and in the judgment. The public employees operating the Williamson County Juvenile Detention Center faced a dilemma. Responsible for the care of up to a dozen minors, those officials had under their supervision one minor, J.H., who, due to mental health concerns, was a threat to himself and others.' Readler's separate writing parses the two prongs of Bell and argues the framework was not designed for in-custody-misconduct scenarios. Captures reasoning/method, not an outcome attributable to him as panel author.
Authored separate writing (NOT a panel disposition; excluded from the appellate-disposition counts). Gibbons, J. (joined by Readler) authored the majority VACATING a preliminary injunction for lack of a live controversy (standing/mootness); Moore, J. dissented. Readler concurred separately. Subject: a First/Fourteenth Amendment challenge to Tennessee election laws, including the state's 'first-time voter' in-person-voting requirement (Tenn. Code Ann. 2-2-115(b)(7)). Grounding quote: 'CHAD A. READLER, Circuit Judge, concurring. With no live controversy between the parties, I agree that the preliminary injunction must be vacated. And should this dispute resurrect itself in some form, it seemingly would take little work to conclude that Tennessee's first-time voter law easily passes constitutional muster.' Illustrates his views on justiciability and on the merits of voter-identity safeguards; reasoning, not an outcome attributable to him as panel author.
Authored separate writing (NOT a panel disposition; excluded from the appellate-disposition counts). Bush, J. (joined by Gilman) authored the majority, which agreed the district court wrongly dismissed for lack of subject-matter jurisdiction but AFFIRMED on the alternative Rule 12(b)(6) ground of res judicata (collateral attack on a state-court consent judgment). Readler concurred in part (agreeing jurisdiction existed) and dissented in part. Grounding quote: 'CHAD A. READLER, concurring in part and dissenting in part. I agree with the majority opinion that the district court should have exercised its jurisdiction over plaintiffs' complaint. For today's purposes, however, I would stop there, leaving the res judicata issue to the district court on remand. ... when we inquired about the issue at oral argument, the point was affirmatively waived by the Township for purposes of this appeal.' Readler invokes the principle of party presentation (United States v. Sineneng-Smith) to argue the panel should not decide an unraised, affirmatively-waived issue. Reasoning/method, not an outcome attributable to him as panel author.
“For the reasons stated above, we AFFIRM the judgment of the district court.”
“For these reasons, we AFFIRM the judgment of the district court.”
“Nonetheless, we VACATE the defendant's sentence and REMAND the case to the district court for resentencing after application of the correct legal standard regarding the use of violence.”
“For these reasons, we AFFIRM the judgment of the district court.”
“For the aforementioned reasons, we affirm the judgment of the district court.”
“For the aforementioned reasons, we affirm the judgments of the district court.”
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