Thomas Q. Langstaff
Judge Langstaff no longer hears cases. This profile is preserved as a historical record of how they ruled.
How Judge Langstaff decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
In Social Security appeals, he reversed and remanded when the ALJ mischaracterized or discounted a treating physician's opinion without adequate reasoning, particularly in conditions like fibromyalgia where objective clinical findings are inherently sparse.
“The lack of objective clinical findings is, at least in the case of fibromyalgia, insufficient alone to support an ALJ's rejection of a treating physician's opinion as to the claimant's functional limitations.”
Procedural preferences
In pro se prisoner civil-rights cases, failure to exhaust administrative remedies under the Prison Litigation Reform Act -- often apparent on the face of the complaint, or from a grievance filed too early or too late relative to the conduct at issue -- was the most common basis for recommending dismissal or partial dismissal, generally without prejudice to refiling once exhausted.
“The Prison Litigation Reform Act, 42 U.S.C. Section 1997e(a), generally requires that a prisoner file an administrative grievance and then appeal any denial of relief through all levels of review that comprise the administrative grievance process before filing suit in federal court.”
As a criminal-duty magistrate, he required a law enforcement officer's first warrant application before him to be presented in person, before permitting that officer's later applications to be attested to by telephone or email under Federal Rule of Criminal Procedure 4.1's remote-attestation procedure.
“Agent Antonio appeared personally before now-retired United States Magistrate Judge Thomas Q. Langstaff on that date to submit the warrant request because U.S. Magistrate Judge Langstaff required law enforcement officers requesting a warrant from him for the first time to participate in the warrant attestation process in-person.”
Cautions
In prisoner civil-rights suits raising multiple claims against multiple defendants, he trimmed cases claim-by-claim and defendant-by-defendant rather than dismissing wholesale, letting adequately pleaded claims proceed against some defendants while dismissing others -- a routine but consistent early-case triage that produced granted-in-part outcomes more often than all-or-nothing ones.
“Petitioner's claims for retaliation and conspiracy against Respondents Sergeant Burks and Remika Christian were sufficiently plead for the purposes of Judge Langstaff's review ... Petitioner's remaining claims for constitutional violations arising from denial of medical care, excessive force and sexual assault, and injunctive relief were found to be without merit.”
Signed rulings
A grounded sample of orders signed by this judge, with the verbatim dispositive language.
“it is the RECOMMENDATION of the undersigned that the Commissioner's decision be REVERSED AND REMANDED pursuant to Sentence Four of Section 405(g) for further consideration in light of this opinion.”
“it is the recommendation of the undersigned that the Commissioner's decision be AFFIRMED pursuant to Sentence Four of Section 405(g).”
“it is the RECOMMENDATION of the undersigned that the petition be DENIED.”
“United States Magistrate Judge Thomas Q. Langstaff's October 15, 2013 Report and Recommendation (Doc. 145) is ACCEPTED, ADOPTED and made the Order of this Court ... Accordingly, the Motions to Dismiss presently under review (Docs. 118, 126, & 128) are GRANTED.”
“The Petitioner has failed to establish ineffective assistance of counsel at trial under the Strickland standard. WHEREFORE, it is recommended that Petitioner's Motion to Vacate, Set Aside, or Correct Sentence Pursuant to 28 U.S.C. Section 2255 (Docs. 169, 170) be DENIED.”
“It is therefore RECOMMENDED that Plaintiff's Complaint be DISMISSED without prejudice, pursuant to Section 1997e and Section 1915A(b)(1), to allow for exhaustion.”
“Petitioner's claims for retaliation and conspiracy against Respondents Sergeant Burks and Remika Christian were sufficiently plead for the purposes of Judge Langstaff's review ... Petitioner's remaining claims for constitutional violations arising from denial of medical care, excessive force and sexual assault, and injunctive relief were found to be without merit.”
“As Defendants have failed to meet their burden as the parties moving for summary judgment, Defendants' Motion for Summary Judgment is DENIED. (Doc. 75).”
“Judge Langstaff concluded that the Motion should be granted because the facts, taken in the light most favorable to the Plaintiff, showed that the Moving Defendants had acted reasonably ... Judge Langstaff found that the Moving Defendants are entitled to qualified immunity.”
“The United States Magistrate Judge ... carefully analyzed and denied Petitioner's habeas petition, finding that the claims therein were procedurally defaulted because they were either (1) not properly exhausted due to Petitioner's failure to petition the Georgia Supreme Court for a certificate of probable cause following the denial of his state habeas petition, or (2) abandoned by Petitioner in his post-hearing brief.”
Caseload & timing
From public federal docket records for this judge.
Sampled dockets were dominated by consent Social Security disability appeals (28 U.S.C. 636(c)), with the remainder split between a consent diversity personal-injury case and criminal-duty matters (initial appearance/detention hearing, a search-warrant application with a nondisclosure order).
A historical record
Judge Langstaff no longer hears cases. This profile stays available as a record of how they ruled. If you're preparing for a matter, start from the court's current bench.