Martha Craig Daughtrey
How Judge Daughtrey rules, drawn from 35 signed orders. Every observation links to the order it came from.
How Judge Daughtrey decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
In rejecting a county's 'officer safety' rationale for a warrantless perimeter search of a home's curtilage, frames the ruling in first-principles constitutional terms rather than resting on doctrinal balancing alone: a recurring rhetorical move when she thinks a government litigant's position would 'swallow the rule.'
“But the Bill of Rights exists to protect people from the power of the government, not to aid the government.”
At the pleading stage, well-pleaded facts need be plausible rather than persuasive, and reasonable inferences are drawn for the claimant.
“forcing the plaintiff’s well-pleaded facts to be not only plausible, but persuasive. That is not the appropriate burden at this stage of the litigation.”
An obstruction-of-justice enhancement based on trial testimony requires specific findings identifying the perjurious statements and satisfying each element of perjury.
“the district court's failure to make the specific findings necessary to enhance Macias-Farias's sentence for obstruction of justice.”
Procedural preferences
Consistent, pointed summary-judgment discipline: when a defendant's argument for affirmance itself assumes disputed facts resolved in its own favor, she calls out the error directly rather than merely reciting the standard: the same discipline later visible in Hostettler v. College of Wooster (2018).
“the very formulation of the defendant's argument betrays the bank's misunderstanding of basic summary-judgment jurisprudence”
Cautions
Notwithstanding her reputation as a notable dissenter in the circuit's highest-profile capital and civil-rights cases, applies AEDPA's procedural time-bars strictly against habeas petitioners in ordinary (non-capital) cases: attorney deadline miscalculation does not excuse an untimely filing, even where the petitioner personally did nothing wrong.
“Attorney miscalculation is simply not sufficient to warrant equitable tolling.”
An interlocutory qualified-immunity appeal cannot proceed when the officer rejects the plaintiff-favorable facts and relies on a disputed account rather than a neat legal issue.
“We have jurisdiction to hear the appeal of a denial of qualified immunity only when ‘the appeal is premised not on a factual dispute, but rather on 'neat abstract issues of law.'’”
Federal habeas relief cannot rest on a right to counsel at a new-trial hearing when no clearly established Supreme Court law recognizes that right.
“there is no ‘clearly established Federal law, as determined by the Supreme Court,’ creating a right to counsel at a hearing on a motion for a new trial”
Racially insensitive workplace comments do not establish a hostile environment unless the context and evidence show conduct sufficiently severe or pervasive to alter employment conditions.
“was not sufficiently severe or pervasive to alter the conditions of employment because the plaintiffs did not show the conduct interfered with their ability to perform their work.”
Signed rulings
A grounded sample of orders signed by this judge, with the verbatim dispositive language.
“we AFFIRM the district court's judgment enjoining implementation of sections 216 and 217 of the Act.”
“The judgment of the district court is REVERSED, and the case is REMANDED for further proceedings consistent with this opinion.”
“we AFFIRM the judgment of the district court denying the petitioner a writ of habeas corpus”
“Because all of these errors involve improper factual determinations, we REVERSE the order of the district court and REMAND the matter for further proceedings consistent with this opinion.”
“we now vacate that COA as improvidently granted”
“We thus DISMISS the appeal for lack of jurisdiction.”
“we AFFIRM the district court's grant of summary judgment to Wal-Mart”
“We therefore REVERSE that portion of the district court's judgment dismissing that claim, AFFIRM the remainder of the judgment, and REMAND the case to the district court for further proceedings.”
“We therefore REVERSE the district court's grant of summary judgment to the defendant and REMAND this matter for such further proceedings as are appropriate.”
“we REVERSE the judgment of the district court insofar as it sets aside the jury's award of punitive damages and REMAND for entry of an order in the district court reinstating and confirming that award”
“we AFFIRM the district court's decision granting summary judgment to the individual officers based on qualified immunity ... we REVERSE the decision of the district court granting summary judgment to the county and the county officials in their official capacities”
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