Sara Lynn Darrow
How Judge Darrow decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
Reads the Computer Fraud and Abuse Act narrowly: mere copying/access or evasion of usage fees is not 'damage' (impairment to the integrity/availability of data); the statute targets data destruction. A civil CFAA plaintiff must also point to record evidence of intent to defraud, not just notice that access went untracked.
“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.”
Procedural preferences
Treats summary judgment as the 'put up or shut up' moment: the non-movant must point to specific record evidence, not rest on characterizations or conclusory assertions. She notes when a brief's record citations are mere '[CITE]' placeholders and holds it against the party.
“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."”
Distinguishes pleading-stage sufficiency from the merits: she will not resolve a fact-bound 'shocks the conscience' substantive-due-process question on a 12(b)(6) motion, letting a state-created-danger claim proceed while dismissing claims that fail as a matter of law.
“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.”
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.”
Disfavors resolving a vigorously-defended case 'on a technicality': she denied a default-judgment motion premised on an untimely answer where no prejudice was alleged.
“This Circuit has a well-established policy favoring a trial on the merits over a default judgment.”
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 = 5 |
Granted: 2Granted in part: 1Denied: 2 | counts only |
| Motions to dismiss N = 2 |
Granted in part: 1Denied: 1 | counts only |
| Motion to reconsider N = 1 |
Denied: 1 | counts only |
| Motion for injunction N = 1 |
Denied: 1 | counts only |
| Default judgment N = 1 |
Denied: 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.
“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.”
“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”
“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.”
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: 101 days (N = 2).
Descriptive from search_dockets nature_of_suit/cause fields across the enumerated Jan-2020 cohort; not an exhaustive census. No FJC IDB baseline present in this record.