Rachel Sarah Bloomekatz
How Judge Bloomekatz decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
Distinguishes controlling precedent by its precise doctrinal domain rather than its surface facts -- owner-liability cases about leaving keys in a car do not govern statutory product-liability claims against a manufacturer, because the two turn on different foreseeability questions. A litigant who frames the analogy at the right level of generality can survive a 12(b)(6) dismissal grounded on adverse precedent.
“We hold that those cases do not control product liability claims against car manufacturers, and that the design defect claims therefore survive.”
Strict, text-anchored reading of appellate jurisdiction under FAA s 16(a): she reviews only the ruling that actually 'denied' the motion to compel and refuses to sweep in related pro-arbitration rulings (contract formation) via pendent jurisdiction, citing the FAA's one-way ratchet favoring arbitration. Judicial-economy arguments do not move her on jurisdiction.
“Section 16(a) allows us to review an interlocutory ruling on contract formation only when that ruling supplied the basis for the district court's denying a motion to compel arbitration.”
On the FAA merits she enforces the 'default' rule with bite: a party that pursues complete victory on the merits in court before invoking arbitration forfeits it. The 'heads I win, tails you lose' posture is fatal.
“By seeking complete victory on the merits in the district court without invoking its arbitration rights even in the alternative, Laundry Service manifested its intent to litigate rather than arbitrate this dispute.”
Signed rulings
A grounded sample of orders signed by this judge, with the verbatim dispositive language.
“We affirm the district court's dismissal of Strench's and Moshi's manufacturing defect and nonconformance claims. We reverse the dismissal of their design defect and warning claims and remand for further proceedings consistent with this opinion.”
“We dismiss Laundry Service's appeal in part for lack of jurisdiction; otherwise we affirm the district court's judgment and deny Schnatter's request for sanctions.”
“We affirm the district court's denial of compassionate release.”
“We therefore reject the Mukhdomis' contention that the fines were grossly disproportional under the Eighth Amendment, and we affirm the district court's imposition of $125,000 in fines for each defendant.”