Robert William Pratt
Judge Pratt no longer hears cases. This profile is preserved as a historical record of how they ruled.
How Judge Pratt decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
Pratt enforces administrative-exhaustion requirements strictly in benefits cases: in the FEHBP context (and citing Eighth Circuit ERISA precedent) he holds that permissive 'may appeal' language in a denial letter or plan document does NOT make the appeal optional -- a claimant on notice of a review procedure must use it before suing. Practical lesson: exhaust every available carrier/OPM (or plan) appeal before filing, and name the correct defendant (for FEHBP, OPM, not the carrier).
“Under Eighth Circuit precedent, the Court must reject Plaintiff's argument that her failure to exhaust administrative remedies is excused.... Accordingly, summary judgment is properly granted in favor of Defendant for Plaintiff's unexcused failure to exhaust.”
On a Rule 12(b)(6) motion Pratt keeps the inquiry on the face of the complaint and resolves fact-sensitive questions (e.g., whether an ERISA fiduciary duty existed) in the plaintiff's favor at the pleading stage, declining to consider extra-pleading documents or convert the motion to summary judgment. He construes 'fiduciary' broadly under ERISA. Practical lesson: a fact-intensive defense (no fiduciary status, contract documents) is unlikely to win dismissal before Pratt -- save it for summary judgment.
“the question at this early stage of the litigation is not whether Defendants will ultimately be found to have been fiduciaries, but whether Plaintiffs have alleged sufficient facts in the Amended Complaint, which taken as true, create a plausible claim to relief.”
Procedural preferences
Pratt holds a movant seeking to limit or establish a right as a matter of law to its strict proof: in the Carmack Amendment context he denied a carrier's partial-SJ motion because the record did not affirmatively show the carrier met every element (here, issuing the bill of lading before shipment), construing the liability-limitation exception narrowly. Practical lesson: a summary-judgment movant before Pratt must put every required element in the undisputed record, not rely on course-of-dealing or post-hoc signatures.
“There is nothing in the record to demonstrate that Start issued the Bill of Lading prior to shipment, nor does Start claim that it issued the Bill of Lading prior to shipment.... Accordingly, at this stage on summary judgment, the Court cannot conclude as a matter of law that Start satisfied the fourth prong of the test”
Signed rulings
A grounded sample of orders signed by this judge, with the verbatim dispositive language.
“Accordingly, for the reasons stated herein, Defendant's Motion for Summary Judgment (Clerk's No. 4) is GRANTED.”
“Plaintiffs Motion for Leave to Amend (Clerk's No. 8) is DENIED because amendment would be futile in light of Plaintiffs failure to exhaust administrative remedies and given that Coventry would not be a proper party in any event.”
“For the reasons stated above, Start's Motion for Partial Summary Judgment (Clerk's No. 21) is DENIED.”
“Defendants' Motion to Dismiss (Clerk's No. 19) is GRANTED IN PART and DENIED IN PART. Specifically, to the extent Defendants request that the Court strike any claim for compensatory damages by Plaintiffs, the motion is granted. It is denied in all other respects.”
“For the reasons stated herein, Plaintiffs' Motion to Strike (Clerk's No. 37) is GRANTED.”
“Petitioners' Motion for Summary Judgment (Clerk's No. 84) is DENIED”
“the State's Motion for Summary Judgment (Clerk's No. 80) is GRANTED”
“the pending motion for summary judgment (Clerk's No. 3) is hereby STRICKEN without prejudice”
“the portion of ‘Plaintiff's Motion for Summary Judgment’ (Clerk's No. 44) pertaining to Count One is DENIED”
“the portion of ‘Defendants' Motion for Summary Judgment’ (Clerk's No. 45) pertaining to Count One is GRANTED”
“Defendant's Motion (Clerk's No. 82) is DENIED”
“Defendants' Supplemental Motion to Dismiss Continental Western's complaint on the basis of issue preclusion (Clerk's No. 55) is GRANTED.”
“The remaining Motions to Dismiss filed by FHFA (Clerk's No. 23) and Treasury (Clerk's No. 24) are DENIED as moot based on the Court's decision.”
“the Court DENIES Defendants' motions for partial summary judgment on Count I”
“this Court holds that the final decision of the Commissioner is not supported by substantial evidence on the record as a whole. This case is reversed and remanded: ed further consideration and for a new decision.”
“this Court holds that the final decision of the Commissioner is not supported by substantial evidence on the record as a whole and is based on legal error. This case is reversed and remanded for further development and a new decision consistent with this opinion.”
“Defendant's Motion to Dismiss or Stay the Proceedings and to Compel Arbitration (Clerk's No. 4) is DENIED.”
Caseload & timing
From public federal docket records for this judge.
Median case duration in the sampled dockets: 949 days (N = 3).
Median motion-to-ruling time: 52 days (N = 5).
The three reviewed civil dockets concern ERISA and employee benefits (Turley and Young) and a commercial contract dispute under the Carmack Amendment (MidAmerican). The available published decisions also include insurance and other commercial disputes. This limited set does not provide a representative nature-of-suit mix for Judge Pratt's full docket.
A historical record
Judge Pratt 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.