Holly Lou Teeter
How Judge Teeter decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
Kansas unjust enrichment requires the plaintiff to have conferred a benefit directly ON the defendant. Buying a product downstream through a distributor does not confer a benefit on the original seller/overhauler; an indirect or no-privity unjust-enrichment claim survives only in limited 'special circumstances' (the defendant misled or induced detrimental reliance, or fraud). To plead it against a remote party, allege those special circumstances, not just that the goods originated with the defendant.
“the undisputed facts show that Plaintiff bought an FCU from a third party that had previously been restored by Defendant. ... Plaintiff has not come forward with facts on which a jury could rely to find that it conferred a benefit on Defendant.”
On summary judgment Teeter holds the movant to its burden and will not decide contract integration/ambiguity on a thin record. A defendant who relies on extrinsic terms sheets to supplement a contract must authenticate and lay a foundation for them and brief the integration/parol-evidence issue in depth; unauthenticated, unsigned documents and 'cursory' or footnoted arguments will not carry summary judgment.
“Defendants’ evidence for inclusion of the term sheets is unauthenticated, unsigned, and lacks any foundational support in the summary-judgment record. And Defendants have not discussed the associated legal issues in any depth.”
Procedural preferences
Treats arguments a party fails to address as conceded. A plaintiff who does not respond to a defendant's standing or merits arguments on a motion to dismiss (or qualified-immunity-style arguments on summary judgment) loses those points; Teeter will dismiss on an unrebutted ground even while noting the result may seem harsh. Respond to every dispositive argument raised.
“National APWU raised this issue in its motion to dismiss. Plaintiff did not respond or point to allegations that would plausibly state a claim. ... Plaintiff has not met her burden on standing, so the Court finds dismissal appropriate on this basis.”
Enforces administrative-exhaustion and limitations deadlines strictly. ADEA: the EEOC charge must be filed within 300 days and must name the correct respondent — charging the local union does not preserve a claim against the national union absent an actual amendment. DFR: a six-month limitations clock that accrues no later than when the plaintiff files an NLRB charge on the same conduct; fraudulent-concealment tolling requires both lack of knowledge and affirmative concealment of the claim itself.
“Plaintiff did file one on March 13, 2023 against the local union. ... But Plaintiff did not amend. She instead waited almost a year and filed another EEOC charge against National APWU on March 13, 2024. This exceeded her deadline by more than ten months.”
On PLRA prisoner suits, exhaustion is screened first and Kansas has TWO distinct administrative avenues (KAR Article 15 inmate grievances vs. Article 16 personal-injury claims). A Section 1983 conditions/medical claim must be exhausted under Article 15; an Article-16 personal-injury claim does not substitute for it. But because exhaustion is an affirmative defense, Teeter will not dismiss on it at the 1915A screening stage before defendants are served — she orders service and sets the dispositive-motion deadline for the exhaustion issue.
“Exhaustion is an affirmative defense, and Defendants have not been served in this case. The Court is ordering service on the remaining Defendants. ... This same deadline shall apply to any dispositive motion on the issue of exhaustion.”
Cautions
A Rule 12(b)(6) dismissal will generally be WITH PREJUDICE when the plaintiff already had a fair chance to fix the defect. Where a defendant's earlier motion flagged the same fatal problem and the plaintiff amended but did not cure it (then chose to stand on the amended complaint rather than seek further leave), Teeter dismisses with prejudice and disapproves of a 'wait-and-see' approach to pleading. Cure known defects in the first amendment, or move for leave; do not stand pat.
“This approach also promotes efficiency and prevents parties from taking a “wait-and-see” approach to see what can get by before making fulsome efforts to address the challenged issues.”
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.
| Summary judgment N = 2 |
Granted in part: 2 | counts only |
| Motions to dismiss N = 1 |
Granted: 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.
“Defendants’ motion for summary judgment (Doc. 52) is denied in part and granted in part.”
“National APWU’s motion to dismiss (Doc. 35) is GRANTED. National APWU is dismissed with prejudice from the case.”
“Defendant’s Motion for Summary Judgment (Doc. 85) is GRANTED IN PART and DENIED IN PART. The motion is denied as to the negligence claim. The motion is granted as to the unjust-enrichment claim.”