Paul Jeffrey Watford
How Judge Watford rules, drawn from 34 signed orders. Every observation links to the order it came from.
Judge Watford no longer sits on this court. This profile is preserved as a historical record of how they ruled here.
About Judge Watford
Paul Jeffrey Watford was a judge of the United States Court of Appeals for the Ninth Circuit. Appointed by President Barack Obama, Judge Watford received a commission on May 22, 2012. Judge Watford resigned on May 31, 2023.
How Judge Watford decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
In reviewing a sentencing enhancement, Watford applied the categorical approach to statutory elements rather than the defendant's conduct. Because none of the alternative elements required the violent force specified by the guideline, consulting conviction documents could not make the offense qualify.
“Without at least one such match, the modified categorical approach has no role to play here.”
In an excessive-force appeal, Watford separated legal questions suitable for interlocutory review from disputes about what the officer actually did. Competing accounts of the shooting had to be resolved by a jury under the summary-judgment standard.
“Factual disputes of that order must be resolved by a jury, not by a court adjudicating a motion for summary judgment.”
Writing for the en banc court in a bankruptcy case, Watford returned to the statutory text and overruled circuit precedent that cut off attorney-fee recovery when an automatic-stay violation ended. The provision covered reasonable fees incurred to obtain the remedy Congress authorized.
“Having reconsidered the matter, we conclude that Sternberg misconstrued the plain meaning of § 362(k).”
Procedural preferences
In consolidated civil-contempt appeals, Watford required a final judgment or another recognized basis for immediate review. The contempt orders could be challenged after final judgment, so the court dismissed the interlocutory appeals and could not reach a related reassignment request.
“We dismiss these consolidated appeals for lack of jurisdiction. As a consequence of that ruling, we also lack jurisdiction to rule on Daleiden and CMP's motion requesting reassignment to a different district judge on remand.”
Cautions
In streamlined immigration proceedings, Watford required a noncitizen alleging denial of counsel to show that the violation could have affected the result. A procedural error alone did not warrant relief when no prejudice from counsel's absence was demonstrated.
“In the circumstances of this case, Gomez-Velazco was required to show prejudice in order to prevail on his due process claim.”
Signed rulings
A grounded sample of orders signed by this judge, with the verbatim dispositive language.
“We vacate his sentence and remand for re-sentencing without the enhancement. VACATED and REMANDED.”
“Accordingly, the district court properly denied his motion to dismiss the felon-in-possession charge.”
“Our holding in Lake Washington controls the outcome here, for the school districts in this case stand on even weaker footing than did their counterpart in Lake Washington. ... AFFIRMED.”
“Having reconsidered the matter, we conclude that Sternberg misconstrued the plain meaning of Section 362(k). To the extent it is inconsistent with this opinion, Sternberg is overruled. ... The judgment of the Bankruptcy Appellate Panel is AFFIRMED.”
“We therefore remand to the BIA with instructions to grant the brothers an opportunity to supplement the record. ... PETITION FOR REVIEW GRANTED; CASE REMANDED.”
“The language of the condition is sufficiently precise to avoid the vagueness concerns we identified in Aquino, and the district court did not abuse its discretion by imposing the condition simply because it prohibits conduct also covered by one of the standard conditions of supervised release. AFFIRMED.”
“PETITIONS FOR REVIEW DENIED.”
“The evidence against Kootswatewa was compelling, and none of the charges turned on whether he 'lured' or merely 'took' K.C. into the abandoned trailer. AFFIRMED.”
“In short, Maricopa County is liable for violations of Title VI and § 12601 stemming from its own official policies.”
“The BIA erred by holding that Section 1231(a)(5) deprived the immigration court of jurisdiction to resolve Miller's motion to reopen. We grant Miller's petition for review and remand the case so that the agency can decide Miller's motion to reopen on the merits. PETITION FOR REVIEW GRANTED; CASE REMANDED.”
“We vacate Edling’s sentence and remand for resentencing.”
“SENTENCE VACATED; REMANDED FOR RESENTENCING.”
A historical record
Judge Watford no longer sits on this court. This profile stays available as a record of how they ruled here. If you're preparing for a matter, start from the court's current bench.