Jonathan Eugene Hawley
How Judge Hawley decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
At summary judgment he wants the non-movant to connect specific evidence to the causal element, not lean on chronology. In the FMLA case he granted the employer's motion because the plaintiff offered only a sequence-of-events theory and could not, even at her own deposition, tie her termination to her leave; he stresses that timing alone is not a nexus.
“Fatally, the Plaintiff does not point to evidence of a nexus between her FMLA leave and her termination that would permit a reasonable jury to find in her favor.”
He reasons carefully through circuit precedent and will treat an appellate court's broad statement as non-binding dictum when a rigorous holding-vs-dictum analysis supports it. He declined to follow Zazu Designs' suggestion that a corporation's wealth is irrelevant to punitive damages, distinguishing the binding sanctions holding from the gratuitous punitive-damages discussion.
“in a case where punitive damages are sought against a corporate defendant, Zazu's statement that the defendant's financial condition is irrelevant to punitive damages is dictum.”
On FLSA collective actions he applies the two-step framework and the lenient step-one standard, and is persuaded by the weight of national authority -- conditional certification of an exotic-dancer misclassification class follows the overwhelming majority of comparable cases, and defenses like arbitration clauses or counterclaims are better addressed at step two.
“If these class members are not similarly situated, it is hard to imagine that a class could ever be conditionally certified, which may also explain why classes were conditionally certified in twenty-five of the twenty-seven cases cited, supra.”
Procedural preferences
He hews closely to controlling circuit precedent even where he finds the result counter-intuitive, but looks for a narrow, principled opening. In an ERISA benefits case he held that conflict discovery is generally barred under Semien/Dennison absent a threshold showing, yet allowed limited discovery on the one question the administrator had 'opened the door' to by an unsupported assertion in the record.
“although somewhat counter-intuitive, one can -- and indeed must -- have specific facts of bias or misconduct before being allowed to conduct discovery into a structural conflict.”
He frames the FMLA performance-standard question precisely along Pagel: the Act does not relax standards for time actually on the job, but does forbid penalizing an employee for protected absences -- and he resolves the case on whether the plaintiff put evidence to that distinction (she had taken only one FMLA day in 2019, a month before the PIP).
“The FMLA does not require an employer to adjust its performance standards for the time an employee is actually on the job, but it can require that performance standards be adjusted to avoid penalizing an employee for being absent during FMLA-protected leave.”
Cautions
Both of his consent-case summary-judgment grants captured here were undone by the Seventh Circuit, in each instance because the appellate court found he resolved a genuine factual dispute (or a sufficiency question) against the non-movant. In Wayland the divided panel held a jury could find OSF failed to adjust its expectations for her approved leave; the dissent agreed with Hawley's causation analysis. A lawyer opposing summary judgment before him should make the disputed-fact and burden record explicit.
“because there is a genuine dispute of material fact over the amount of approved leave Wayland took ... we vacate the judgment and remand for trial.”
In the prisoner 1983 case his summary judgment turned on PLRA exhaustion; the Seventh Circuit reversed, holding that a single grievance about an ongoing condition can exhaust without successive filings. Counsel should be ready for him to enforce exhaustion strictly at summary judgment, and conversely to brief the 'continuing violation' exhaustion line where it applies.
“the district court erred in granting summary judgment to the defendants on the ground that Boyce failed to exhaust his administrative remedies as required by the PLRA.”
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: 2 | counts only |
| Class certification N = 1 |
Denied: 1 | counts only |
| Motions to compel N = 1 |
Granted: 1 | counts only |
| Conditional certification N = 1 |
Granted: 1 | counts only |
| Motion for discovery N = 1 |
Granted in part: 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.
“Ryan's Motion for Discovery Authorization (D. 9) is GRANTED in part and DENIED in part.”
“The motion is GRANTED.”
“the motion to compel (D. 27) is GRANTED.”
“Defendant OSF Healthcare System's Motion for Summary Judgment (Doc. 19) is GRANTED. The Clerk is directed to terminate this case.”
“the district court ... granted summary judgment for failure to exhaust Boyce's Eighth Amendment claim.”
“The district court denied, however, Boyce's motion to file a class action lawsuit, reasoning that "a prisoner bringing a pro se action cannot represent a class of plaintiffs."”
Caseload & timing
From public federal docket records for this judge.
Median case duration in the sampled dockets: 464.5 days (N = 8).
Median motion-to-ruling time: 109.5 days (N = 2).
Descriptive from search_dockets nature_of_suit/cause fields across the enumerated consent (2019-2023) and district-judge (2026) cohorts; NOT an exhaustive census. No FJC IDB baseline (disposition_mix) loaded -- his consent cases mostly terminated AFTER the ~2021-06-30 IDB snapshot, so idb_data is null and disposition_mix is omitted (expected, per runbook).