Deborah Louise Cook

How Judge Cook rules, drawn from 36 signed orders. Every observation links to the order it came from.

Court
U.S. Court of Appeals for the Sixth Circuit
Position
circuit
Appointed by
George W. Bush (Republican)
Commissioned
2003-05-07
Education
University of Akron (B.A., 1974); University of Akron School of Law (J.D., 1978)
Signed orders read
36

How Judge Cook decides

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

What persuades

Applies a categorical, elements-focused approach to sentencing-enhancement questions (ACCA/Guidelines 'crime of violence'), matching a state offense's statutory elements against the generic federal definition rather than the facts of the underlying conduct, and treats an unraised distinction as forfeited rather than reaching it sua sponte.

“If the statute requires proving that someone used, attempted, or threatened to use physical force against another, it satisfies the elements clause even if the statute does not match the elements clause word for word.”

Willing to overturn the circuit's own stale precedent en banc when a fresh textual analysis demands it, rather than preserving institutional inertia: here reversing a categorical zero-privacy rule for booking photos under FOIA Exemption 7(C).

“We overrule Free Press I, reverse the grant of summary judgment, and remand to the district court for proceedings consistent with this opinion.”

In administrative and agency-enforcement remedies, insists remedies be tailored to the violation rather than punitive or symbolic, closely policing NLRB remedial orders for First Amendment / compelled-speech overreach.

“Remedies may not be used as an instrument of punishment.”

In benefits disputes, she holds plan administrators to the definitions they wrote and requires a reasoned explanation addressing evidence that fits those definitions. A denial for lack of objective findings was arbitrary when the plan expressly counted medications and treatment plans, yet the administrator ignored both.

“It never explained why his medications and treatment plan failed to satisfy the plan’s objective-findings definition. Nor did its rejection letters offer any other explanation for the benefits denial. Accordingly, the Administrator’s decision was arbitrary and capricious.”

She treats public-comment rules that suppress criticism or offense as viewpoint discrimination, even in a limited public forum. Terms such as antagonistic, abusive, and personally directed were invalid because they favored praise over opposition rather than neutrally regulating a subject or disruption.

“These terms plainly fit in the ‘broad’ scope of impermissible viewpoint discrimination because, like in Matal, Iancu, and American Freedom Defense Initiative, they prohibit speech purely because it disparages or offends.”

Procedural preferences

She requires strict compliance with Rule 11's safe harbor before sanctions are available. Warning letters and informal notice do not substitute for serving the actual motion early enough to permit withdrawal or correction.

“Permitting litigants to substitute warning letters, or other types of informal notice, for a motion timely served pursuant to Rule 5 undermines these goals.”

She distinguishes a mandatory claim-processing deadline from a jurisdictional bar, but still enforces the deadline when an equitable-tolling theory was not preserved and lacked supporting authority. Nonjurisdictional does not mean optional.

“These rules, which ‘promote the orderly progress of litigation by requiring that the parties take certain procedural steps at certain specified times . . . are quintessential claim-processing rules’ that the Supreme Court treats as nonjurisdictional.”

An agreement delegating arbitrability to an arbitrator is independently enforceable unless the party specifically challenges that delegation clause. An attack on the loan agreement as a whole did not authorize the court to decide enforceability itself.

“Only a specific challenge to a delegation clause brings arbitrability issues back within the court’s province.”

Signed rulings

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

Detroit Free Press Inc. v. United States Department of Justice
14-1670 · 2016-07-14
Appeal (appellant) Granted

“We overrule Free Press I, reverse the grant of summary judgment, and remand to the district court for proceedings consistent with this opinion.”

Sysco Grand Rapids, LLC v. National Labor Relations Board
19-2371/2421 · 2020-09-04
Petition for review (petitioner) Granted in part

“We GRANT the petition for review in part, GRANT the cross-application for enforcement in part, and ENFORCE the Board's order as modified by this opinion.”

Steiger v. Hahn
16-2531 · 2018-01-03
Appeal (appellant) Denied

“We AFFIRM the district court's judgment.”

NTCH-West Tenn, Inc. v. ZTE Corp.
17-6469/17-6524 · 2019-01-16
Appeal (appellant) Denied

“AFFIRM the district court's dismissal for lack of personal jurisdiction, and DISMISS defendant's cross-appeal as moot.”

Knology, Inc. v. Insight Communications Co., L.P.
03-5674 · 2004-12-29
Appeal (appellant) Granted

“The Noerr-Pennington doctrine insulates Insight from liability for its activities here, we reverse the district court's decision.”

Wiegand v. United States
02-2555 · 2004-08-19
Appeal (appellant) Granted

“We reverse the district court's decision and remand for the district court to determine whether the Supreme Court's decision in Jones v. United States ... established a new AEDPA limitations period.”

Casillas-Figueroa v. Gonzales
04-3221 · 2005-08-12
Petition for review (petitioner) Denied

“For the following reasons, we affirm the BIA and deny the petition.”

United States v. Williams
04-6255 · 2006-01-31
Appeal (appellant) Denied

“Because the district court reasonably sentenced Williams, we affirm.”

United States v. Schmeltz
11-3140 · 2011-12-20
Appeal (appellant) Denied

“We accordingly AFFIRM Schmeltz's conviction.”

Bartholomew v. Blevins
11-5809 · 2012-05-17
Appeal (appellant) Denied

“We AFFIRM.”

United States v. Banks
10-6242 · 2012-05-18
Appeal (appellant) Denied

“Because Banks fails to distinguish Donald Graham, we decline to categorically prohibit the consideration of juvenile-age offenses ... Accordingly, we AFFIRM.”

Jones v. City of Cincinnati
11-4174 · 2012-11-29
Appeal (appellant) Granted

“Because the record demonstrates that the officers did not act objectively unreasonably, we REVERSE.”

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