Staci Michelle Yandle
How Judge Yandle 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 applies the liberal Rule 8 / Iqbal-Twombly plausibility standard generously: she accepts the complaint's allegations as true, draws reasonable inferences for the plaintiff, and lets a claim proceed where the facts plausibly state a claim -- even against a defendant's factual denials, which are not for resolution on a 12(b)(6) motion.
“Drawing inferences in Plaintiff's favor, her allegations are sufficient to meet Rule 8's liberal pleading requirements. ... Dismissal for failure to state a claim is proper only if the plaintiff can prove no set of facts in support of her claims which would entitle her to relief.”
Procedural preferences
PLRA administrative exhaustion is decided FIRST and is dispositive: the defendant bears the burden, but once the records show no qualifying grievance and the prisoner identifies no record facts creating a genuine dispute, she grants summary judgment for failure to exhaust and dismisses WITHOUT prejudice. Merits evidence is irrelevant to the exhaustion question. (In S.D. Ill. this is frequently routed through a magistrate-judge Report & Recommendation that she adopts.)
“Neither Plaintiff's response nor his summary judgment motion identifies any facts in the record to demonstrate the existence of a genuine material factual dispute on the issue of exhaustion. Accordingly, summary judgment in Lochard's favor is warranted.”
She enforces the proper-defendant rule in prisoner cases: for injunctive relief the warden of the institution (in official capacity) is the proper defendant, not the IDOC -- and she will cure the defect by substituting the warden rather than letting the suit fail on a naming technicality.
“When a prisoner seeks injunctive relief, the proper defendant is the warden of the institution where the prisoner is located. ... the Clerk of Court is DIRECTED to add the Warden of Menard Correctional Center in their official capacity as a defendant.”
Cautions
She expects litigants to prosecute and comply with court orders: after a clear warning, an unexplained failure to respond to discovery or communicate with the court draws a Rule 41(b) dismissal WITH PREJUDICE.
“Plaintiff was warned that his failure to respond to the discovery requests or communicate with the Court would result in the dismissal of this case pursuant to Fed. R. Civ. P. 41(b) without further notice. ... this case is DISMISSED with prejudice for failure to prosecute.”
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: 2Denied: 1 | counts only |
| Summary judgment N = 3 |
Granted: 2Denied: 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.
“For this reason, Defendant IDOC's motion to dismiss is GRANTED. IDOC shall be dismissed with prejudice and judgment entered accordingly at the conclusion of this litigation. However, the Clerk of Court is DIRECTED to add the Warden of Menard Correctional Center in their official capacity as a defendant.”
“Drawing inferences in Plaintiff's favor, her allegations are sufficient to meet Rule 8's liberal pleading requirements. ... Here, there are sufficient factual allegations in Plaintiff's Complaint to allow her FDCPA claim to proceed against the Defendants. Accordingly, Defendants' motion to dismiss is DENIED.”
“The Motion for Summary Judgment filed by Defendant Dr. Hughes Lochard on exhaustion of administrative remedies (Doc. 56) is GRANTED. Defendant Lochard is DISMISSED from this action without prejudice.”
“Plaintiff's Motion for Summary Judgment/Evidence (Doc. 60) is DENIED.”
“Accordingly, Defendants' motions for summary judgment for failure to exhaust administrative remedies (Docs. 78, 80, and 81) are GRANTED. Plaintiff's claims are DISMISSED without prejudice and the Clerk of Court is DIRECTED to close this case.”
“Accordingly, this case is DISMISSED with prejudice for failure to prosecute and failure to comply with a court order. Fed. R. Civ. P. 41(b). The Clerk of Court is DIRECTED to close this case and to enter judgment accordingly.”