Edmond E-Min Chang
How Judge Chang 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 treats a 'self-serving' affidavit as legitimate, admissible evidence that can defeat the motion -- but it must contain specific, first-hand facts, not broad-brush conclusory assertions; a vague affidavit that omits dates, names, and record support will not create a triable issue.
“evidence presented in a 'self-serving' affidavit or deposition is enough to thwart a summary judgment motion. ... There is nothing wrong with 'self-serving' averments in an affidavit, so long as they comprise admissible evidence.”
In a Title VII case where the employer cites performance/attendance as its reason, he merges the prima-facie 'legitimate expectations' prong with the pretext inquiry -- so a plaintiff must rebut the honesty of the stated reason, not just dispute the underlying facts.
“the question whether Snorton-Pierce was meeting the Tollway's legitimate expectations merges with the question whether the Tollway's reasons for firing her are honest.”
Procedural preferences
He enforces Local Rule 56.1 even against pro se litigants, but only after fair warning: here he had directed the pro se plaintiff to read the rule and contact the Pro Se Help Desk, and the movant served the required Rule 56.1 notice -- then deemed the movant's facts admitted when the plaintiff still failed to respond properly.
“Federal courts may enforce their local rules, such as Local Rule 56.1, even as to pro se litigants like Akbar. ... The Court accordingly deems the facts outlined in Interstate's Statement of Facts admitted, and disregards Akbar's unsupported factual assertions.”
He will NOT give preclusive (res judicata) effect to a state administrative agency's decision unless the record affirmatively shows the agency acted in a judicial capacity with the usual safeguards (counsel, discovery, cross-examination, findings). A defendant invoking agency preclusion must build that record; a bare assertion fails.
“res judicata can only apply when an administrative agency is acting in a judicial capacity and resolves disputed issues of fact properly before it which the parties have had an adequate opportunity to litigate.”
Cautions
Section 1983 requires state action: a private company contracting with a public housing authority or HUD is NOT acting under color of state law unless it was delegated a public function and the state controlled its conduct. Plaintiffs suing private contractors under 1983 must plead and prove that nexus.
“Although Interstate is contracted with the Chicago Housing Authority, a municipal not-for-profit organization, this does not mean the private corporation was acting under color of state law.”
He applies the federal exhaustion and jurisdictional doctrines strictly: a citizenship-declaration claim under 8 U.S.C. 1503 must complete the full N-600 / administrative-appeal process first, and Illinois's IIED tort is construed 'very narrowly' -- conduct must go 'beyond all possible bounds of decency,' a bar that an unreasonable refusal alone does not clear.
“Because Vavrinek did not exhaust his administrative remedies before bringing this lawsuit, as 8 U.S.C. 1503 requires him to do, and the Federal Defendants have not waived this requirement, the complaint must be dismissed for failure to exhaust administrative remedies.”
On a Rule 12 motion he will prune the remedies as well as the claims: he strikes punitive and exemplary damages requests from statutory employment claims that do not permit them, and limits liquidated damages to the claims that authorize them (here, ADEA). Plead only the damages the statute allows for each count, or expect them struck.
“requests for punitive and exemplary damages are struck from the remaining counts, and requests for liquidated damages are struck from all remaining counts except Haag's ADEA claims (Counts 3 and 4).”
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.
| Motions to dismiss N = 8 |
Granted: 3Granted in part: 2Denied: 3 | counts only |
| Summary judgment N = 6 |
Granted: 3Denied: 3 | counts only |
| Motions to strike 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.
“The motion to dismiss Metra's counterclaim is denied.”
“For the reasons discussed above, the Court grants Defendants' motions to dismiss [R. 26, 27, 37].”
“For the reasons described above, there are genuinely disputed material facts on Miranda's retaliation claim, so Auto Wares' motion for summary judgment is denied.”
“For the reasons above, Interstate's motion for summary judgment is granted and Akbar's motion for summary judgment is denied.”
“For the reasons above, Interstate's motion for summary judgment is granted and Akbar's motion for summary judgment is denied.”
“For the reasons stated above, the Tollway's motion for summary judgment [R. 33] is granted.”
“The Office of the Chief Judge's motion to dismiss is granted in large part.”
“For these reasons, the Amended Complaint is dismissed, but Akbar may file a second amended complaint by August 26, 2020, naming Interstate and Legends as defendants.”
“MAM's motion to dismiss is granted in part and denied in part.”
“The motion for summary judgment, R. 166, is denied.”
“For the reasons discussed below, the motions to dismiss by AKA Sorority and Walker-Steele are granted, but the other motions are denied.”
“For the reasons discussed below, the motions to dismiss by AKA Sorority and Walker-Steele are granted, but the other motions are denied.”
“Mondelez's motion to dismiss and for fees and costs is denied.”
“For the reasons discussed below, the motion for summary judgment is granted in full and the motion to strike and for sanctions is granted in part and denied in part.”
“For the reasons discussed below, the motion for summary judgment is granted in full and the motion to strike and for sanctions is granted in part and denied in part.”
Caseload & timing
From public federal docket records for this judge.
Median case duration in the sampled dockets: 1258 days (N = 2).
Median motion-to-ruling time: 309 days (N = 1).
Active judge. His current (2026) docket is a typical busy N.D. Ill. civil/criminal mix: Schedule A IP/counterfeiting cases (Toyota, Aiting/Kalyty patent, copyright), ADA Title III access suits (Lamperis v. Turbo Holdings), Social Security appeals (Booth/Davenport v. Bisignano), employment (Higuera-Alvarez v. TJX), prisoner/BOP matters, and federal criminal. Historically he handled the influential BIPA biometric-privacy line (Rivera v. Google) and FICO/turkey-style antitrust MDLs. Nature-of-suit only partially reported in docket case-level metadata.