Robert William Pratt
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”
Motion outcomes
Counted from classified signed orders only. Percentages are shown only where the sample is large enough to be meaningful; smaller samples are reported as raw counts.
| Summary judgment N = 2 |
Granted: 1Denied: 1 | counts only |
| Motions to dismiss N = 1 |
Granted in part: 1 | counts only |
| Motion for leave to amend N = 1 |
Denied: 1 | counts only |
| Motions to strike N = 1 |
Granted: 1 | counts only |
A "1 of 1" is one ruling, not a tendency. Treat small samples as illustrative, not predictive.
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.”
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).
Pratt's FULL assigned docket was not enumerated this session (a surname search returns party-Pratt cases, not his caseload). The 3 confirmed Pratt dockets read here are ERISA/employee-benefits (Turley, Young) and a commercial contract/Carmack case (MidAmerican). From search_case_law, his reported civil work clusters in ERISA/employee-benefits, insurance, and commercial disputes; he was also a prominent critic of the Sentencing Guidelines (Gall v. United States affirmed his below-guidelines sentence). A no-query, assigned_judge-filtered sweep is needed for a real nature-of-suit mix.