Sara Lynn Darrow
How Judge Darrow rules, drawn from 16 signed orders. Every observation links to the order it came from.
About Judge Darrow
Sara Lynn Darrow is a judge of the United States District Court for the Central District of Illinois. Appointed by President Barack Obama, Judge Darrow received a commission on August 3, 2011.
Judge Darrow's practices and standing orders
The court's website lists no individual practices or standing orders of Judge Darrow's own (checked October 9, 2026), so the court's local rules and general orders are the place to look (court page ↗).
Standing orders for every case in this court
Orders the court applies to all of its cases, whichever judge has them, as published on the court's website (checked October 9, 2026).
How Judge Darrow decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
In Fidlar Technologies v. LPS Real Estate Data Solutions, Darrow granted LPS summary judgment on the Computer Fraud and Abuse Act claims. She held that the particular access and SOAP calls did not constitute damage to data under section 1030(a)(5)(A), and found insufficient evidence of intent to defraud under section 1030(a)(4).
“Neither the bare act of accessing the middle tier without using Fidlar's client, nor the generation of SOAP calls that failed to contain usage and print information, are ‘damage’ under § 1030(a)(5)(A). LPS is entitled to judgment on the § 1030(a)(5)(A) claim as a matter of law.”
On qualified immunity the plaintiff bears the burden of defeating it; a novel constitutional theory without closely analogous controlling precedent fails the 'clearly established' prong, and a later or out-of-circuit case (decided after the conduct) cannot supply it.
“no such right was ‘clearly established’ at the time Bebber allegedly misinformed DeMont about her eligibility for benefits. Bebber is therefore entitled to qualified immunity, and the Court grants summary judgment in his favor on Count II.”
Requires a federal-officer removal theory to connect the asserted liability to conduct under federal direction. An express disclaimer excluding military-contract contamination defeated jurisdiction even though that contamination could still be raised as an alternate cause.
“Permitting Defendant to remove this suit under the federal officer removal statute when the federal government contractor defense is irrelevant to the eventual resolution of the case and any PFAS it produced as a military contractor is explicitly excluded from this suit would defeat the purpose of the statute.”
In Baez-Sanchez v. Kolitwenzew, she ordered an individualized bond hearing after finding that more than four years of immigration detention without one violated due process in the case’s circumstances.
“The Court finds that, given the unique factual circumstances of Baez-Sanchez's case and the length of his detention, Baez-Sanchez's continued detention without a bond hearing is unreasonable and violates the Due Process Clause.”
Procedural preferences
In Fidlar Technologies v. LPS Real Estate Data Solutions, Inc., she granted the defendant summary judgment after examining the record evidence and finding the plaintiff had not shown the required intent, statutory damage, or interference.
“Summary judgment is the ‘put up or shut up moment in a lawsuit, when a party must show what evidence it has that would convince a trier of fact to accept its version of events.’”
In Eilenfeldt ex rel. J.M. v. United C.U.S.D. 304 Board of Education, she allowed a state-created-danger claim to proceed because whether the alleged conduct shocked the conscience was fact-bound on those pleadings.
“whether certain conduct shocks the conscience is ‘a necessarily fact-bound inquiry,’ and not appropriately decided, on these facts, at the motion-to-dismiss stage.”
Reconsideration is an 'exacting' and rare remedy: losing-party disappointment is not enough.
“A manifest error is not demonstrated by the disappointment of the losing party. It is the wholesale disregard, misapplication, or failure to recognize controlling precedent.”
An accommodation proposal must identify the essential job function the disability prevents and explain how the proposed change would permit performance. Extra time to obtain tenure after an adverse review was treated as a second chance, not a required accommodation.
“A reasonable accommodation ‘is one that allows the disabled employee to “perform the essential functions of the employment position,”’ but it is not clear what essential function of her position Plaintiff supposedly could not perform or how her proposed accommodations would facilitate them”
In Rutherford v. Peoria Public Schools District 150, she granted an employee partial summary judgment after finding prejudice from the district’s failure to give FMLA notices before delaying reinstatement.
“Simply put, the District’s failure to follow the FMLA notice rules, and thereby prolonging Rutherford’s reinstatement process, prejudiced Rutherford because it kept him from returning to work despite the fact that he wanted to, was fit to do so, and was entitled to do so.”
Cautions
The class-of-one equal-protection bar is high: a plaintiff must plead facts negating any conceivable rational basis. Where defendants had ordinary pedagogical/disciplinary discretion, labeling their conduct 'bullying' or 'retaliation' without supporting facts does not overcome the presumption of rationality.
“If there is a ‘conceivable rational basis for the difference in treatment’ suffered by the class member, then the claim fails.”
In Board of Trustees of the University of Illinois v. Micron Technology, Inc., she denied default judgment over an untimely answer where no prejudice was alleged, citing the Circuit's policy favoring resolution on the merits.
“This Circuit has a well-established policy favoring a trial on the merits over a default judgment.”
Qualified immunity may remain unresolved at summary judgment when entitlement turns on disputed facts about what an officer observed and knew. In the detainee-medical-care case, the factual dispute over obvious distress prevented immunity at that stage.
“The question of whether Defendant Whitsel violated Kee’s constitutional rights turns on resolution of the factual disputes identified above, thus precluding a ruling on whether Defendant Whitsel is entitled to qualified immunity at this stage.”
In one Social Security appeal, Judge Darrow rejected objections that asked the court to reweigh medical and daily-activity evidence after finding the administrative decision logical and supported by substantial evidence.
“The ALJ’s decision was logical, explained, and based upon substantial evidence.”
In a habeas case, the court declined equitable tolling where records showed serious mental illness but did not show that it had actually prevented the petitioner from managing his affairs during the filing period. The petition was dismissed as untimely.
“Petitioner has not met his burden of showing that his mental illness prevented him from managing his affairs in such a profound way as to qualify as exceptional circumstances.”
Signed rulings
A grounded sample of orders signed by this judge, with the verbatim dispositive language.
“the Court GRANTS Defendant Dan Bebber's Motion for Summary Judgment [22] on DeMont's two claims and DENIES Plaintiff Betty J. DeMont's Motion [18] on those counts. This matter is now TERMINATED.”
“LPS's Motion for Summary Judgment, ECF No. 77, is GRANTED and summary judgment is granted as to all counts of Fidlar's Amended Complaint, ECF No. 31-1. Because the motion is granted in its entirety, LPS's Alternative Motion for Partial Summary Judgment on Certain of Fidlar's Claims for Damages, ECF No. 79, is MOOT.”
“the Motion to Dismiss, ECF No. 36, is GRANTED IN PART and DENIED IN PART, the Motion for Leave to File Memorandum in Excess of Page Limitation is GRANTED, and the Motion to Supplement is DENIED.”
“the Court DENIES Defendants' Motion for Summary Judgment, ECF No. 36, GRANTS IN PART and DENIES IN PART Plaintiffs' Motion for Partial Summary Judgment, ECF No. 61”
“As this is Micron's only challenge to the University's standing, Micron's motion to dismiss for lack of subject matter jurisdiction, ECF No. 146, is DENIED.”
“Micron's Motion to Reconsider or Certify for Interlocutory Appeal, ECF No. 97, is DENIED.”
“The University's Renewed Motion for In-junctive Relief, EOF No. 108, is DENIED.”
“The University's Motion for Default Judgment, EOF No. 121, is DENIED.”
“Plaintiff People of the State of Illinois, ex. rel. Kwame Raoul, Attorney General of the State of Illinois’s Motion to Remand, ECF No. 3, is GRANTED. This suit is remanded back to the Circuit Court of the Fourteenth Judicial Circuit, Rock Island County.”
“Plaintiff’s request for attorney’s fees is therefore denied.”
“Accordingly, Defendant Board of Trustees of Western Illinois University’s (‘WIU’) motion for summary judgment, ECF No. 18, is GRANTED. The Clerk is directed to enter judgment and close the case.”
“The County Defendants’ Motion for Summary Judgment [115] is GRANTED as to Plaintiff’s claims against Defendants Flaugher, Warrick, Largent, Walter, and Diericks in Count I, Plaintiff’s claims against Defendants Macon County and Macon County Sheriff in Count II, Plaintiff’s claims against Defendants Largent, Flaugher, Diericks, Warrick, and Walter in Counts IV and V, and Plaintiff’s claims in Count X as they relate to the Crossing Defendants. The motion is DENIED as to any other relief requested.”
“The Crossing Defendants’ Motion for Summary Judgment [116] is GRANTED as to Plaintiff’s claims against Defendants Ray and Thompson in Count I, and Plaintiff’s claims against Defendant Crossing Healthcare and Defendants Ray and Fasick in their official capacities in Count III. The motion is DENIED as to any other relief requested.”
“The Commissioner’s decision denying Tammie benefits is AFFIRMED.”
“GRANTS Respondent’s Motion to Dismiss (Doc. 19)”
“DENIES Petitioner’s Motion to Request Counsel (Doc. 18)”
“This motion (doc. 22) is dismissed as a duplicative filing.”
“For the reasons set forth below, the Petition is GRANTED and the Court orders that Petitioner be granted an individualized bond hearing.”
“BNSF's Motion for Summary Judgment, ECF No. 55, is DENIED in part and GRANTED in part.”
“BNSF's Motion for Leave to File Reply in Excess of Page Limitation, ECF No. 57, is GRANTED.”
Caseload & timing
From public federal docket records for this judge.
Median case duration in the sampled dockets: 375 days (N = 13).
Median motion-to-ruling time: 253 days (N = 20).
The reviewed January 2020 matters provide a descriptive caseload mix rather than an exhaustive census. Administrative case-ending data are not available for this record.
Pending matters in the official report
Reported by the Administrative Office of the U.S. Courts under the Civil Justice Reform Act, as of March 31, 2026.
| Motions pending more than six months | 1 |
| 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 | 8 |
| Report | Motions over six months | Cases over three years |
|---|---|---|
| Mar 2026 | 1 | 8 |
| Sep 2025 | 0 | 6 |
| Mar 2025 | 0 | 7 |
| Sep 2024 | 0 | 14 |
| Mar 2024 | 2 | 19 |
| Sep 2023 | 3 | 35 |
| Mar 2023 | 1 | 34 |
| Sep 2022 | 0 | 24 |
| Mar 2022 | 15 | 17 |
| Sep 2021 | 2 | 9 |
| Mar 2021 | 0 | 7 |
| Sep 2020 | 3 | 1 |
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.
How long civil cases take in this court
For the whole of U.S. District Court for the Central District of Illinois, not for Judge Darrow: median time from filing to disposition of the civil cases the court closed in the 12 months ending September 30, 2025, as reported by the Administrative Office of the U.S. Courts.
| Cases | Median time | |
|---|---|---|
| All civil cases closed | 760 | 7.3 months |
| Closed with no court action | 315 | 6.2 months |
| Closed before pretrial | 438 | 8.4 months |
| Closed during trial | 7 | not reported |
| 12 months ending | Cases closed | Median time |
|---|---|---|
| Sep 2025 | 760 | 7.3 months |
| Sep 2024 | 704 | 8 months |
| Sep 2023 | 625 | 10.8 months |
| Sep 2022 | 637 | 11.7 months |
| Sep 2021 | 684 | 9.9 months |
| Sep 2020 | 629 | 10.4 months |
| Sep 2019 | 653 | 10.1 months |
The table leaves out prisoner petitions, land condemnations, deportation reviews, recovery of overpayments and enforcement of judgments, and reports no median for fewer than 10 cases. A district that closed a large multidistrict litigation in the period shows very large counts and long medians for that year. Source: Table C-5, U.S. District Courts (spreadsheet).
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