Karen LeCraft Henderson

U.S. Court of Appeals for the District of Columbia Circuit circuit Appointed by George H.W. Bush (Republican) 31 signed orders read

How Judge Henderson decides

Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.

What persuades

She reads a FOIA exemption no more broadly than the specific secret it protects -- a statute that seals one narrow category of information does not, by extension, seal every record that happens to touch on it, but she will uphold a broad Glomar refusal to confirm or deny records exist where the agency's own declaration plausibly explains how even a partial answer could reveal intelligence sources or methods.

“A tendency need only make a result more likely.”

In separation-of-powers and executive-detention disputes, she looks to whether Congress used mandatory, all-inclusive language ('shall,' 'any') -- if it did, she treats the agency as having no discretion to carve out an exception no matter how sympathetic the agency's practical rationale.

“The word 'shall' makes the directive to regulate hazardous-waste-derived fuels mandatory... And the repeated use of 'any' makes the mandate broadly inclusive.”

Procedural preferences

She holds parties to negotiated settlements even after the legal landscape shifts underneath them -- a later ruling that the settled-upon legal regime was preempted or invalid does not reopen a knowing release of claims whose value was uncertain when the parties struck their bargain.

“[A] change in the law does not render an agreement void.”

Jurisdiction and standing come first: a claim of injury that depends on a chain of future contingencies -- a bid being placed, a nonexistent entity being formed, a regulator later deciding to sue -- does not clear Article III's threshold no matter how sound the underlying legal argument might be.

“KCC's alleged harm stacks speculation upon hypothetical upon speculation, which does not establish an actual or imminent injury.”

Cautions

An agency loses when it cannot explain, in its own order, how it grappled with a governing statute -- reciting cases about a related but distinct problem is not the same as addressing the actual statutory conflict raised, and a reviewing court will not fill that gap for the agency.

“Because the Board failed to address the relevant statutory provisions, we grant the Hospital's petition for review, deny the Board's cross-petition for enforcement and remand to the Board for proceedings consistent herewith.”

A warning or order aimed at specific, identified misconduct will not be read to sweep in future protected activity just because its language could, in isolation, be stretched that broadly -- context and the conduct that actually prompted the warning control.

“No reasonable employee in Kaanta's position could read it otherwise.”

Signed rulings

A grounded sample of orders signed by this judge, with the verbatim dispositive language.

Patrick Eddington v. United States Department of Defense
21-5074 · 2022-06-03
Appeal (appellant) Denied

“For the foregoing reasons, the district court's grant of summary judgment is affirmed.”

Murphy v. Executive Office for United States Attorneys
14-5044 · 2015-06-16
Appeal (appellant) Denied

“For the foregoing reasons, the district court's judgment is affirmed.”

William A. Davy, Jr. v. Central Intelligence Agency
· 2006-09-18
Appeal (appellant) Granted

“For the foregoing reasons, we reverse the district court order and remand for proceedings consistent with this opinion.”

Thomas E. Moore, III v. Central Intelligence Agency
10-5248 · 2011-12-20
Appeal (appellant) Denied

“Accordingly, we affirm the district court's grant of summary judgment to the CIA.”

Electronic Privacy Information Center v. Department of Justice (BuzzFeed/Leopold)
20-5364 · 2021-11-30
Appeal (appellant) Granted in part

“Accordingly, we reverse the district court's grant of summary judgment to DOJ on its Exemption 7(C) withholding claims for the information regarding the Special Counsel's declination decisions on the purported campaign violations... In all other respects, we affirm the district court's grant of summary judgment to DOJ on its Exemption 7(C) withholding decisions.”

Bilal Abdul Kareem v. Gina Cheri Haspel
19-5328 · 2021-01-15
Appeal (appellant) Moot / procedural

“Accordingly, we vacate the district court's dismissal pursuant to the state secrets privilege and remand with instructions to dismiss the complaint on the ground that Kareem lacks Article III standing.”

Assassination Archives and Research Center v. Central Intelligence Agency
02-5003 · 2003-07-08
Appeal (appellant) Denied

“For the foregoing reasons, we affirm the judgment of the district court.”

Vern McKinley v. Board of Governors of the Federal Reserve System
10-5353 · 2011-06-03
Appeal (appellant) Denied

“For the foregoing reasons, we affirm the district court's grant of summary judgment in favor of the Board.”

Dover Energy, Inc., Blackmer Division v. National Labor Relations Board
14-1197 (consolidated with 14-1221) · 2016-03-22
Petition for review (petitioner) Granted

“Because the record -- viewed with the deference due the Board -- lacks substantial evidence in support of the Board's decision, we grant Blackmer's petition and deny the Board's cross-application for enforcement.”

Camelot Terrace, Inc. and Galesburg Terrace, Inc. v. National Labor Relations Board
12-1071 (consolidated with 12-1218) · 2016-06-10
Petition for review (petitioner) Granted in part

“We agree that the Board lacks authority to require the reimbursement of litigation costs incurred during Board proceedings... but hold that the Board may require an employer to reimburse a union's bargaining expenses pursuant to its remedial authority under section 10(c) of the Act... Accordingly, we grant the Companies' joint petition in part and grant the Board's cross-application for enforcement in part.”

Salem Hospital Corporation v. National Labor Relations Board
11-1466 (consolidated with 12-1009) · 2015-12-15
Petition for review (petitioner) Denied

“For the foregoing reasons, we deny Salem's petition for review and grant the Board's cross-application for enforcement.”

Comau, Inc. v. National Labor Relations Board
10-1406 (consolidated with 10-1409) · 2012-03-02
Petition for review (petitioner) Granted

“For the reasons set forth below, we grant Comau's petition and vacate the Board's finding that Comau committed a ULP by unilaterally changing its employees' healthcare benefits.”

Put Judge Henderson's record to work

Ezel drafts and answers grounded in this exact profile: how Judge Henderson actually rules, not a generic AI guess.

Opens in Ezel Pro. Every answer is grounded in Judge Henderson's own signed orders and cites them.