Philip G. Reinhard
How Judge Reinhard decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
He decides statutory/regulatory questions as questions of law and is willing to rule for the taxpayer on cross-MSJs where the agency reads an exception too broadly: in the I.R.C. Section 199 'domestic production deduction' context he held that a complex production process yielding a 'distinct final product' is MPGE, not the excepted 'packaging/repackaging,' adopting the reasoning of United States v. Dean and rejecting the government's argument that Dean was wrongly decided.
“Dean correctly determined that Houdini was creating an entirely new product - a gift basket or gift tower - which was not simply a method of repackaging the components included in the baskets or towers. ... Likewise, a unit dose is a unique product. Plaintiff is entitled to the Section 199 deduction.”
Procedural preferences
On a purely legal question of regulatory interpretation he treats proffered expert opinion as neither necessary nor helpful and declines to consider it: the meaning of the regulatory text is for the court, so motions turning on expert testimony are denied as immaterial to the legal issue.
“The decision in this case depends on a legal interpretation of 26 C.F.R. 1.199-3(e)(1) & (2). The court did not consider the opinions of these proffered experts in interpreting the regulation as the meaning of the language of the regulation is for the court to determine. No expert opinion is necessary or helpful to that interpretation.”
When dismissing on the pleadings he often dismisses without prejudice and grants leave to replead to a fixed deadline rather than dismissing outright, but pairs the leave with an express warning that failure to cure by the deadline will convert the dismissal into one with prejudice.
“Plaintiffs are given leave to file a second amended complaint ... on or before May 22, 2020. Plaintiffs are warned that failure to file a second amended complaint on or before May 22, 2020 will result in the dismissal of this case with prejudice.”
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 = 3 |
Granted: 1Granted in part: 1Denied: 1 | counts only |
| Summary judgment N = 3 |
Granted: 2Denied: 1 | counts only |
| Motion for reconsideration 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 Commissioner's motion to dismiss [6] is granted. This case is dismissed without prejudice.”
“For the reasons stated below, defendant's motion to dismiss [34] is denied. Plaintiffs are given leave to file a second amended complaint seeking judicial review of the denial of their claim for benefits on or before May 22, 2020.”
“Defendants' motion to dismiss on the basis of improper joinder [20] is granted in part and denied in part. The court dismisses as improperly joined plaintiff's claim against defendant Heath. The court instructs the clerk to terminate Heath as a defendant in this matter.”
“For the foregoing reasons, the government's motion [186] for summary judgment is denied.”
“Plaintiff's motion [183] for summary judgment is granted. ... Judgment is entered in favor of plaintiff and against defendant in the amount of $72,522 for the 2007 refund and $74,146 for the 2008 refund plus statutory interest on both.”
“For the reasons set forth below, defendant's motion for summary judgment [73] is granted.”
“For the reasons stated below, Tri-Dim's motion [170] to reconsider or in the alternative to grant Tri-Dim leave to file a motion for summary judgment is denied.”
Omnibus procedural/case-management order resolving four non-dispositive motions. Verbatim disposition: 'For the reasons stated below, plaintiff's motion [489] to retransfer this case is denied, defendants' motion [460] to bar is denied, plaintiff's motion [462] to clarify is denied, and defendants' motion [454] to strike is granted.' Recorded as an order read; excluded from motion stats because all four are procedural (retransfer/evidentiary-bar/clarify/strike), not dispositive merits rulings.
Sua sponte screening of an in forma pauperis complaint under 28 U.S.C. 1915(e)(2)(B)(ii). Verbatim: 'For the reasons stated below, this case is dismissed pursuant to 28 U.S.C. 1915(e)(2)(B)(ii) for failure to state a claim upon which relief can be granted.' The plaintiff's motion for attorney representation [4] was denied and the IFP application [3] denied as moot. Counts as an order read, not a party-motion ruling; excluded from motion stats per the screening convention.
Caseload & timing
From public federal docket records for this judge.
Median case duration in the sampled dockets: 119.0 days (N = 17).
Sampled recent (2022-2024) terminated filings assigned to 'Philip Godfrey Reinhard'. As a senior judge his enumerable docket skews to transportation/personal-injury negligence against trucking and delivery companies, insurance subrogation/coverage (multiple Owners Insurance Co. cases), ERISA/disability-benefits (UNUM, MetLife), ADA and other employment, FDCPA/consumer-finance, and a steady undercurrent of pro se prisoner and civil-rights matters (Winnebago County Sheriff, Dixon Correctional). Nature-of-suit codes are frequently blank in docket for these dockets; the few labeled are 445 (ADA-employment), 110 (Contract: Insurance), 190 (Contract: Other), and 440 (Civil Rights: Other).