Robert William Pratt
How Judge Pratt rules, drawn from 24 signed orders. Every observation links to the order it came from.
Judge Pratt no longer hears cases. This profile is preserved as a historical record of how they ruled here.
About Judge Pratt
Robert W. Pratt was a judge of the United States District Court for the Southern District of Iowa. Appointed by President William J. Clinton, Judge Pratt received a commission on May 27, 1997. Judge Pratt assumed senior status on July 1, 2012 and served until death on January 28, 2026.
How Judge Pratt decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
In Turley v. Coventry Health Care of Iowa, Pratt granted the carrier summary judgment because the claimant had not exhausted the available administrative appeal to the Office of Personnel Management. He held that permissive wording in the plan did not excuse exhaustion.
“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.”
In Young v. Principal Financial Group, Pratt held that the former plan participants plausibly alleged an ERISA fiduciary claim at the pleading stage. He declined to decide fiduciary status from documents outside the complaint, while dismissing a separate claim for compensatory damages.
“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
In MidAmerican Energy Co. v. Start Enterprises, Pratt denied the carrier’s partial summary judgment motion because the record did not show that it issued the bill of lading before shipment, a required element of its proposed liability limit.
“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 is ... GRANTED.”
“The State’s Motion for Summary Judgment is GRANTED as to the dismissal of Petitioners Timothy Phelps and Elizabeth Phelps, and DENIED in all other respects.”
“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 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.
Pending matters in the official report
Judge Pratt was last listed in the Civil Justice Reform Act report as of September 30, 2023.
| Motions pending more than six months | 0 |
| Bench trials submitted more than six months | 0 |
| Bankruptcy appeals pending more than six months | 0 |
| Social Security appeals pending more than six months | 0 |
| Civil cases pending more than three years | 0 |
| Report | Motions over six months | Cases over three years |
|---|---|---|
| Sep 2023 | 0 | 0 |
| Mar 2023 | 4 | 2 |
| Sep 2022 | 2 | 3 |
| Mar 2022 | 0 | 1 |
| Sep 2021 | 1 | 1 |
| Mar 2021 | 1 | 0 |
| Sep 2020 | 2 | 0 |
A snapshot on that date: matters listed may since have been decided or reassigned. A motion referred to a magistrate judge is counted for both judges. Motions in multidistrict litigation, section 2255 cases and Social Security appeals are not counted, and a very large three-year count is generally a multidistrict docket. Source: Appendix A of the report (PDF); about the report.
A historical record
Judge Pratt no longer hears cases. This profile stays available as a record of how they ruled here. If you're preparing for a matter, start from the court's current bench.