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.”
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.”
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.”
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”
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.”
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.”
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.”
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.
Put Judge Darrow's record to work
Ezel drafts and answers grounded in this exact profile: how Judge Darrow actually rules, not a generic AI guess.
Opens in Ezel Pro. Every answer is grounded in Judge Darrow's own signed orders and cites them.