Michael J. Reagan
Judge Reagan no longer hears cases. This profile is preserved as a historical record of how they ruled.
How Judge Reagan decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
On a Section 1983 conspiracy claim against private citizens, he applies the Brokaw framework: a private individual who conspires with a state actor is subject to liability, and at the pleading stage the complaint need only allege the essential who, what, when, why, and how of the conspiracy. Concrete allegations of the parties, the purpose, and the approximate date and place carry such a claim past a motion to dismiss.
“Plaintiff’s allegations are on all-fours with Brokaw because she alleged that the Howsers conspired with Quick and Adams (a sheriff and a county attorney) to deprive her of custody of her child. ... the allegations are not too vague to imagine how jurisdiction exists over the parties.”
Procedural preferences
He treats PLRA exhaustion as a threshold issue resolved on summary judgment after a Pavey hearing, and where no party objects to the magistrate judge's report he adopts it without de novo review, dismissing unexhausted claims without prejudice.
“The period in which such objections may be filed has expired, so pursuant to 28 U.S.C. § 636(b)(1)(B) this Court need not conduct de novo review. ... ADOPTS Magistrate Judge Williams’ Report and Recommendation (Doc. 33) in its entirety and GRANTS Nwaobasi’s motion for summary judgment”
On Rule 60(b) he holds relief to be an extraordinary remedy and will not use the 60(b)(6) catch-all where an enumerated subsection applies; but he will, reluctantly, grant relief to reach what he sees as the correct result and conserve judicial resources rather than leave a litigant to refile.
“While considering it to be a stretch to grant Coleman’s motion under 60(b)(6), the Court is willing to make that stretch because it serves judicial efficiency and economy as well as obtaining what the Court perceives to be a correct result.”
Cautions
In prisoner free-exercise cases he requires a substantial burden on religious practice, not a de minimis one: occasional improperly prepared meals do not state a constitutional claim. He also reads First Amendment retaliation narrowly, looking at whether the alleged retaliation would deter the protected activity (filing grievances) rather than some other conduct, and applies Iqbal to bar supervisory liability absent the official's own personal involvement.
“De minimis burdens on the free exercise of religion, such as denial of a pork-free diet on three occasions out of 810 meals, are not of constitutional dimension. ... The second prong of the retaliation claim requires that Plaintiff would likely be deterred from filing grievances ... not that he would likely be deterred from adhering to his religious diet.”
Signed rulings
A grounded sample of orders signed by this judge, with the verbatim dispositive language.
“Accordingly, the Defendants' Motion to Dismiss is hereby DENIED.”
“the undersigned District Judge ADOPTS Magistrate Judge Williams’ Report and Recommendation (Doc. 33) in its entirety and GRANTS Nwaobasi’s motion for summary judgment (Doc. 13). Plaintiff’s § 1983 claim against Defendant Nwaobasi is DISMISSED without prejudice.”
“the Court DENIES Chase’s motion to voluntarily dismiss its claim against the United States and remand to state court (Doc. 21).”
“Defendants’ Motion for Summary Judgment (Doc. 138) Is GRANTED IN PART AND DENIED IN PART”
“the Court ADOPTS in its entirety the Report and Recommendation (Doc. 122). ... All claims against Defendants Seip and Martin are DISMISSED with prejudice for failure to exhaust administrative remedies regarding the contents of those claims”
“the Court GRANTS Plaintiff Sheryl Coleman’s motion for relief from judgment (Doc. 32) and VACATES the September 19, 2008, grant of summary judgment entered against Coleman.”
Caseload & timing
From public federal docket records for this judge.
Median motion-to-ruling time: 29.5 days (N = 2).
A representative caseload mix and reliable case-duration median could not be computed because Reagan's merits docket was reassigned after his 2019 retirement, leaving the available name-matched cases dominated by unrelated closed administrative matters. His written work reflects a general civil and criminal docket with a substantial prisoner civil-rights component.
A historical record
Judge Reagan no longer hears cases. This profile stays available as a record of how they ruled. If you're preparing for a matter, start from the court's current bench.