William Alan Fletcher
How Judge Fletcher rules, drawn from 39 signed orders. Every observation links to the order it came from.
How Judge Fletcher decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
Requires a particularized showing before restricting access to discovered information.
“A district court must find ‘good cause’ before issuing a protective order restricting access to discovered information.”
Enforces a state's strong public policy when assessing whether a contractual forum-selection clause should control.
“We hold that the forum-selection clause at issue here contravenes the strong public policy announced by Idaho Code § 29-110(1) and is therefore unenforceable.”
In a criminal case, Fletcher required evidence satisfying the precise statutory meaning of an essential value element. Proof that property had archaeological importance could not substitute for proof of value under the charged theft statute.
“Because the government introduced no evidence other than ‘archaeological value’ to prove that Ligón and Mizell stole something of ‘value’ belonging to the government in violation of § 641, the district court should have granted their motions for acquittal.”
In a Chapter 13 case, Fletcher read a later statutory provision as a targeted exception permitting modification of a short-term home-secured claim. A plan proponent should tie the proposed treatment to the claim's payment schedule and the exception's specific text.
“§ 1322(c)(2), enacted after Nobelman was decided, creates an exception to § 1322(b)(2) for claims that are paid off during the life of the bankruptcy plan.”
Fletcher treated allegations of fabricated evidence and other bad-faith police conduct as capable of reopening probable cause despite an earlier preliminary-hearing determination. A civil-rights plaintiff should identify the specific misrepresentation or manipulation rather than merely relitigate the prior finding.
“Scafidi’s allegations of ‘fabricated evidence, or other wrongful conduct undertaken in bad faith’ create a triable issue of material fact as to probable cause.”
In the categorical approach, he will not carry a mens rea attached to one statutory element into a separate results element; the elements must match as Congress wrote them, even when the real-world offense involved intentional violence.
“we believe it is improper to ‘carry forward’ the mens rea requirement of some elements of § 1958(a) to the separate death-results element.”
Procedural preferences
Returns issues for first-instance analysis when the trial court applied the wrong governing standard.
“We reverse and remand for the court to apply the proper standard in ruling on Bolin’s Rhines motion.”
Treats statutory time limits as controlling even when a later reopening might seem administratively convenient.
“Under the regulations, the only ground on which the ALJ could have reopened after two years lapsed was ‘fraud or similar fault.’”
When enforcing a foreign judgment, Fletcher treated a voluntary merits appearance as a waiver of personal jurisdiction even though the defendant also preserved a jurisdictional objection. A party seeking to contest jurisdiction should limit its participation to that defense until the issue is resolved.
“We hold that Rejuvi waived its personal jurisdiction defense under the Uniform Act by voluntarily appearing in the South Australian district court in an attempt to set aside the 2016 default judgment.”
For an electronically delivered agency decision, he measures receipt by effective access rather than the date an unusable encrypted file arrived; counsel's documented efforts to obtain a readable decision also supported equitable tolling.
“We hold that the 90-day limitation period did not begin until Luiz could realistically be held responsible for having access to the FAD and learning what the agency had decided.”
He keeps jurisdiction separate from the merits: when reviewing dismissal for lack of subject-matter jurisdiction, arguments about whether the plaintiff will ultimately win do not answer whether a court may hear the claim.
“The merits of Ibarra-Perez’s case are not before us. The question before us is whether the district court has jurisdiction to decide those merits.”
Cautions
At summary judgment, insists that disputed facts be viewed in the nonmovant's favor before qualified immunity is granted.
“Viewing the facts of this case in the light most favorable to Appellees, Officers Myers and Beecroft are not entitled to qualified immunity on a motion for summary judgment.”
In a consumer-arbitration appeal, Fletcher required a plaintiff to establish standing for each challenged fee and remanded when the trial court had not addressed whether she actually paid one of them. Pleading a class theory does not replace concrete proof that the named plaintiff suffered the particular charge.
“The district court did not address the issue of Spruell’s standing to challenge the $1.99 expedited payment fee in its order denying RAC’s motion to compel arbitration. We remand to allow the district court to do so.”
Signed rulings
A grounded sample of orders signed by this judge, with the verbatim dispositive language.
“The decision of the Benefits Review Board is AFFIRMED.”
“We therefore AFFIRM the district court’s dismissal.”
“AFFIRM the decision of the district court.”
Draft for Judge Fletcher with the record in hand
Ezel grounds your drafting and research in this profile: what has persuaded Judge Fletcher, and what has not, cited to the signed orders.
Opens in Ezel Pro.
- Grounded in Judge Fletcher's own signed orders
- Cites every source it relies on, so you can verify it
- Chat, drafting and research in one workspace