Rebecca R. Pallmeyer
How Judge Pallmeyer decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
At the pleading stage she pointedly refuses to import summary-judgment-era proof requirements: she relaxed the 'plaintiff must have applied for the promotion' rule because the plaintiff plausibly alleged she was deterred by her manager's discriminatory conduct.
“Hudson and other summary judgment cases on which Defendant relies assume a fully-developed record; they do not control the resolution of a motion to dismiss.”
In ERISA cases she applies deferential arbitrary-and-capricious review and reads the futility exception narrowly -- a claimant must show the administrative appeal was CERTAIN to fail, not merely likely -- and she enforces exhaustion (including of discrete sub-issues such as the monthly benefit amount).
“In order for the futility exception to the exhaustion requirement to apply, Nelson would have to show that it is certain that his claim would have been denied on appeal.”
In statutory/arbitration disputes she defers to the arbitrator's factual findings (clear-error) but reviews legal conclusions de novo, and will reach the right result on a cleaner rationale than the arbitrator's -- here resolving an ERISA/MPPAA-vs-bankruptcy conflict so as not to reanimate discharged debt.
“Giving Plaintiff less than 100% credit for its Alden liability would do just that by effectively reanimating discharged debt, thereby significantly impairing bankruptcy law.”
She prunes complaints count-by-count and defendant-by-defendant rather than dismissing wholesale: a single order can grant dismissal of one count or one defendant while letting the rest proceed (e.g. dismissing only the IIED Count VI, or dismissing one individual defendant for lack of personal-guarantee liability while the corporate claims continue).
“For the reasons stated above, Dugan's motion to dismiss [34] is granted as to Count VI, and otherwise denied.”
Procedural preferences
She strictly enforces N.D. Ill. Local Rule 56.1: a summary-judgment non-movant who fails to file a proper statement of additional facts has the movant's facts deemed admitted. Lawyers opposing her MSJs must file a compliant 56.1(b)(3) statement or lose the factual record.
“All material facts set forth in the statement required by the moving party will be deemed to be admitted unless controverted by the statement of the opposing party.”
On Daubert/expert challenges she will limit rather than wholesale-exclude an expert, but draws a firm line at legal conclusions -- an expert may not opine on ultimate legal issues.
“Expert witnesses may not provide legal conclusions on ultimate legal issues.”
Cautions
Monell municipal-liability claims need evidence of a widespread practice, not a single bad episode -- a lone incident of injury and rough treatment will draw summary judgment for the local government.
“Plaintiff has failed to offer so much as a theory, let alone any evidence, that would suggest his injuries were the result of a practice or pattern of activity by Defendants or that any such pattern existed.”
She regards motions to strike as a disfavored, drastic remedy and will deny one absent real prejudice or confusion -- do not file Rule 12(f) motions reflexively.
“Courts generally disfavor and infrequently grant motions to strike.”
Genuine factual disputes defeat summary judgment even for a sympathetic movant: where the parties dispute what was said or represented, she denies SJ and sends the fact question to trial rather than resolving it on the papers.
“The parties' dispute about what True Value employees told Erwin about the new RGA program precludes summary judgment in favor of True Value on the question of whether the Second RGA was supported by new consideration.”
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 = 13 |
Granted: 4Granted in part: 3Denied: 4Moot / procedural: 2 | 54% granted |
| Summary judgment N = 7 |
Granted: 3Granted in part: 2Denied: 2 | counts only |
| Motion to confirm or vacate arbitration award N = 2 |
Granted in part: 2 | counts only |
| Motions to strike N = 1 |
Denied: 1 | counts only |
| Motion to bar expert testimony 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.
“Defendant's motion for summary judgment (26) is granted.”
“Defendants' Motion for Summary Judgment [51] is granted.”
“MEMORANDUM Opinion and Order ... motions to dismiss 24 30 are denied. Signed by the Honorable Rebecca R. Pallmeyer on 6/21/2019.”
“Plaintiff's motion to enforce the award in part [21] is granted ... Both parties' motions are denied to the extent that they seek to vacate or modify, in part, the arbitration award.”
“as is Defendant's motion to enforce, in part, the arbitration award [28]. Both parties' motions are denied to the extent that they seek to vacate or modify, in part, the arbitration award.”
“Defendants' motion to dismiss Plaintiff's request for future economic benefits or pain and suffering damages is granted.”
“Defendants' motion to strike the jurisdictional allegations in the Amended Complaint is denied without prejudice.”
“Defendants' prior motion to dismiss [16, 17] is terminated as moot.”
“Defendant's motion for summary judgment [30] is granted.”
“Plaintiff's motion for summary judgment [33] is denied, and the Clerk is directed to enter judgment in favor of Defendant and against Plaintiff.”
“Accordingly, Defendant's motion to dismiss [23] is denied.”
“For the foregoing reasons, Defendant's Motion for Summary Judgment [82] is granted with respect to Saitta's hostile work environment claims (Claims One and Two) and denied with respect to Saitta's retaliation claims (Claims Three and Four).”
“Defendant's second Motion to Dismiss [23] is granted in part, and Defendant's first motion [13] is stricken.”
“The motion to dismiss [17] is granted and Defendant Palmberg is dismissed from this case without prejudice.”
“Defendant's motion to dismiss Plaintiffs' First Amended Complaint [29] is granted.”
“Assurance's motion to bar [110, 114] is granted in part and denied in part, in accordance with this opinion.”
Caseload & timing
From public federal docket records for this judge.
Median motion-to-ruling time: 195 days (N = 6).
As a senior judge (since 2024-08-01) Pallmeyer still draws a full mixed docket. The most recent slice (2026) is dominated by newly-filed PENDING civil cases, heavily Western Division/Rockford (3:26-cv-50xxx dockets: e.g. Daniel v. General Motors, Kathrein v. Arcadia Consumer Healthcare [370 Other Fraud], Flemming v. City of Rockford, Moore v. Trans Union [FCRA], Insurance King v. Allstate [110 Insurance]), plus Chicago-Division product-liability tied to her NEC MDL (O'Malley/Spangler v. Abbott/Mead Johnson). Nature-of-suit is mostly unreported in the docket case-level metadata for this slice.