Doris L. Pryor
How Judge Pryor decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
Textualism that refuses to read terms into a contract or statute that are not there. In a contract with no mediation timeline she declines to invent one for either side and sends the reasonableness question to the factfinder.
“the Agreement leaves a 'yawning void' that 'cries out for an implied term' as to the mediation timeline. ... We are not convinced by either party's attempt to read in contract language that does not exist.”
In statutory eligibility disputes she anchors on what the sentencing record actually shows the judge did, not on what the statute would have permitted -- the moving party must point to findings actually made.
“determining the statute of conviction for First Step Act purposes does not depend on what the sentencing judge could have done. What matters instead is what the sentencing judge did. ... Judge Randa never made the requisite findings to trigger 848(b)'s heightened penalties.”
In constitutional-vagueness review she looks past a statute's superficially objective terms to ask whether it actually cabins official discretion, and treats an admission of unfettered case-by-case discretion at oral argument as fatal.
“Without such guidance, any on-duty officer can use the buffer law to subject any pedestrian to potential criminal liability by simply ordering them not to approach... The Fourteenth Amendment will not tolerate a law subjecting pedestrians to arrest merely because a police officer had a bad breakfast.”
Procedural preferences
Independent, sua sponte assurance of appellate jurisdiction -- party agreement does not create it; she will dismiss rather than infer an assignment the docket does not show.
“The parties maintain that we have jurisdiction ... But their agreement does not make it so. We must independently assure ourselves of our jurisdiction in every case. ... We see no virtue in permitting our jurisdiction to depend on inferences where both the statute and common sense call for precision.”
Strict enforcement of administrative prerequisites: a Title VII plaintiff must have an EEOC right-to-sue letter before suing; a blanket 'in the process of receiving it' will not do.
“Before bringing a Title VII claim, a plaintiff must first exhaust his administrative remedies by filing charges with the EEOC and receiving a right to sue letter. ... Neither Plaintiffs' proposed amended complaint nor appellate briefing reflect that any specific plaintiff obtained a right to sue letter.”
Distinguishes a mere 'bald assertion' of compliance from record evidence that actually creates a triable dispute -- a sworn declaration plus corroborating contemporaneous documentation is enough to defeat summary judgment on exhaustion, even against contrary agency records.
“we have more than a 'bald assertion' that Breyley timely filed a complaint on January 2. Breyley stated in a sworn declaration that he filed a complaint on January 2... He corroborated his declaration with a copy of his journal entry.”
Cautions
If the district court rests on multiple independent grounds (e.g. forfeiture AND the merits), the appellant must contest every one; leaving an independent ground unchallenged waives the appeal of that claim.
“Where a party 'lose[s] in the district court on multiple grounds,' such as 'forfeiture and the merits,' that party 'must contest all on appeal; prevailing on one won't suffice.' ... Because forfeiture went unaddressed on appeal ... we find Plaintiffs have waived their ability to appeal these claims.”
A due-process property/liberty interest must be pleaded concretely; paying tuition does not by itself create a contractual right not to be suspended, and speculative future-career harm does not meet the 'stigma plus' liberty test.
“attending a university does not automatically create a constitutional property right. ... the allegations merely speculated about the suspension's stigmatizing effect.”
An argument affirmatively urged below cannot be flipped into an appellate challenge -- asking a district court to adopt a specific factual finding waives any later attack on that same finding.
“A defendant waives an argument that a sentencing decision was erroneous when, before the district court, his lawyer argued in favor of the sentencing decision that the defendant seeks to challenge on appeal... Pugh waived any challenge to the attribution on appeal.”
Signed rulings
A grounded sample of orders signed by this judge, with the verbatim dispositive language.
“Because Malhotra did not meet the threshold requirement of pleading a property or liberty interest, we AFFIRM the district court's judgment dismissing his complaint.”
“For these reasons, we VACATE the grant of EPI's motion for summary judgment and REMAND for further proceedings consistent with this opinion.”
“We agree with the district court that Plaintiffs' claims are either improperly preserved or inadequately pled. We further find the district court did not err in declining to afford Plaintiffs an additional opportunity to file a proposed amended complaint ... For these reasons, we AFFIRM.”
“Accordingly, we find no abuse of discretion in the district court's decision to not apply equitable tolling to Pettis's claim under the judicial recusal statute, 28 U.S.C. 455. ... For these reasons, we AFFIRM the judgment of the district court.”
“Because the turnover motion in this case was not properly assigned to the magistrate judge, the order issued by the magistrate judge was not an appealable, final decision. As such, we lack appellate jurisdiction to rule on the motion. ... The appeal is DISMISSED.”
“The district court did not clearly err in finding that Walker was sentenced under 848(a). This offense, for purposes of a sentencing reduction, does not qualify as a 'covered offense' pursuant to the First Step Act. For those reasons, we AFFIRM the district court's denial of Walker's motion for First Step Act relief.”
“Because the ALJ in this case did precisely that when concluding that Baptist could perform light work and because her decision is supported by substantial evidence, the denial of benefits must be upheld.”
“For these reasons, we AFFIRM in part, REVERSE in part, and REMAND for proceedings consistent with this opinion.”
“In sum, Ellison showed that she lacks meaningful access to the Postal Service's program without an accommodation. We therefore VACATE the grant of summary judgment in favor of the Postal Service and REMAND for further proceedings on whether Ellison's proposed accommodation is reasonable.”
“Unfortunately for Sargeant, his claim falls outside of the narrow category of suits allowed under today's doctrine. ... For these reasons, we AFFIRM the judgment of the district court.”
“In sum, under our precedent, Thompson made false statements within the meaning of 18 U.S.C. Section 1014. ... For these reasons, we AFFIRM the district court's judgment.”
“For these reasons, we VACATE Wilcher's sentence and REMAND for a full resentencing hearing.”
Put Judge Pryor's record to work
Ezel drafts and answers grounded in this exact profile: how Judge Pryor actually rules, not a generic AI guess.
Opens in Ezel Pro. Every answer is grounded in Judge Pryor's own signed orders and cites them.