John Zihun Lee
How Judge Lee rules, drawn from 37 signed orders. Every observation links to the order it came from.
How Judge Lee decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
In an employment case, Lee read the ADA's remedial provisions together rather than treating a medical-inquiry violation as categorically outside disability-discrimination relief. Because the statute itself defined the violation as discrimination on the basis of disability, the employee could seek back pay even without proving an actual or perceived disability.
“We affirm the district court's restoration of Nawara's seniority, but because the ADA defines a violation of § 12112(d)(4) to be discrimination ‘on the basis of disability,’ we reverse the district court's denial of Nawara's request for back pay and remand for further proceedings.”
In an arbitration dispute previously decided in state court, Lee began with the federal full-faith-and-credit statute and applied the rendering state's preclusion law. The state judgment barred a second decision on the same contract issue in the later federal action.
“Section 1738 of Title 28 requires federal courts to give state court judgments the same preclusive effect as they would be given under the law of the rendering state.”
In a disability-benefits appeal involving fibromyalgia, Lee required the agency's analysis to account for symptoms across time rather than rely on a few normal examinations. A longitudinal review was necessary to connect the medical record to the claimant's functional capacity.
“As SSR 12-2p recognizes, such a longitudinal review is critical to forming the ‘logical bridge’ between the medical records and the ALJ's conclusions regarding the impact of Swiecichowski's fibromyalgia on her functional capacity.”
Procedural preferences
In reviewing whether an amended collateral claim related back, Lee focused on fair notice in the circumstances of the litigation, not merely a facial comparison of the two pleadings. That contextual inquiry favored relation back where both claims concerned counsel's handling of the same sentencing-enhancement notice.
“In making this assessment, district courts also must consider whether, under the particular circumstances of the litigation, the opposing party has been put on notice as to the claim raised in the proposed amendment.”
Cautions
In a sanctions appeal, Lee treated silence about controlling adverse precedent as more than weak advocacy. The court affirmed dismissal and awarded appellate fees and costs after the appellant barely acknowledged the earlier decision that foreclosed his position.
“We have held repeatedly that appellants risk Rule 38 sanctions when they litigate in the face of controlling adverse authority that they pretend does not exist.”
Signed rulings
A grounded sample of orders signed by this judge, with the verbatim dispositive language.
“The district court granted summary judgment after concluding that no reasonable jury could find in Gamble's favor as to any of her claims. We agree and affirm the judgment.”
“The district court dismissed Robbin's complaint under Federal Rule of Civil Procedure 12(b)(6), determining that he failed to state a federal claim, and declined to exercise supplemental jurisdiction over the state law claims. We affirm.”
“The judgment of the district court is AFFIRMED. Defendant Sam Harmelech's Rule 38 motion for damages and costs is GRANTED. Mac Naughton is hereby ordered to pay the costs and reasonable attorney's fees Sam Harmelech has incurred for defending this appeal.”
“Reynolds now appeals the revocation and argues that the district court erred because it failed to recognize its discretion to consider substance abuse treatment as an alternative to revocation and incarceration. We affirm.”
“The district court sided with Beach Forwarders and entered judgment on the pleadings, holding that the contract was terminable at will. We affirm.”
“Given the state court's decision, the district court determined that the doctrine of issue preclusion blocked Uber from relitigating the effect of the arbitration agreements on Zurek's claims that arose after his opt-out of the arbitration agreement in the 2022 PAA and denied Uber's motion to compel arbitration as to Zurek. Uber appeals. ... Because we find the district court's analysis to be sound, we affirm.”
“McCombs appeals, arguing that she was entitled to a mitigating role reduction under the United States Sentencing Guidelines Manual (‘U.S.S.G.’) § 3B1.2, in part because one of her co-conspirators received this reduction. ... Because the district court's conclusions were not clearly erroneous, we affirm.”
“The district court dismissed the RICO claims under Federal Rule of Civil Procedure 12(b)(6) and denied supplemental jurisdiction as to the state law claims. We affirm.”
“We affirm the district court's restoration of Nawara's seniority, but because the ADA defines a violation of § 12112(d)(4) to be discrimination ‘on the basis of disability,’ we reverse the district court's denial of Nawara's request for back pay and remand for further proceedings.”
“Because the district court abused its discretion in reaching that conclusion, we reverse and remand for further proceedings as to Coleman's amended ineffective assistance of counsel claim.”
“The district court denied Johnson's habeas petition, concluding that his DNA-related claim was procedurally defaulted and the state court reasonably applied federal law when determining that the State had not acted in bad faith when discarding the blood sample. We affirm.”
“Because Plaintiffs have not alleged an adequate injury, we agree that they lack standing to bring this suit and affirm the district court's dismissal of the case on jurisdictional grounds.”
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