Sarah S. Vance
How Judge Vance decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
On diversity jurisdiction she weighs a litigant's stated intent against objective domicile facts and credits a party's own prior conflicting representations in other proceedings; a self-serving statement of citizenship 'is entitled to little weight if it conflicts with the objective facts.'
“Mendy's conflicting statements in different legal proceedings about his domicile indicate that his current representations lack candor and credibility.”
In Deepwater Horizon 'B3'/BELO toxic-tort cases she grants summary judgment where a plaintiff has no admissible expert on general or specific causation: expert testimony is required because the causal link between oil/dispersant exposure and the claimed conditions is not within a layperson's common knowledge.
“Because plaintiff is unable to sustain his burden on causation, the Court grants summary judgment.”
Procedural preferences
Rule 56(d) is taken seriously: a summary-judgment motion filed before adequate discovery will be denied as premature where the nonmovant identifies specific, outcome-relevant evidence it cannot yet obtain. 'Rule 56(d) motions are broadly favored and should be liberally granted.'
“Defendants have therefore met their burden under Rule 56(d), and plaintiffs' motion for partial summary judgment is denied.”
Strict on Local Rule 7.5 deadlines: an opposition memorandum filed late may be disregarded entirely ('the Court therefore need not consider any arguments or evidence submitted in [the] untimely filing'), though here she addressed it anyway and the outcome held.
“Plaintiff's opposition memorandum was untimely. See E.D. La. L.R. 7.5 ... The Court therefore need not consider any arguments or evidence submitted in Mendy's untimely filing.”
On a Rule 12(b)(6) motion she holds the line on the pleadings-only rule: documents attached to the motion are considered only if the complaint refers to them and they are central to the claim; otherwise considering them impermissibly converts the motion to summary judgment.
“the records cannot be considered in ruling on the motion to dismiss without converting it into a motion for summary judgment”
Reads Carswell v. Camp narrowly on qualified-immunity discovery stays: a complete stay is mandatory only while a QI motion to dismiss is pending. Where a defendant forgoes the MTD and raises QI at summary judgment (to rely on video), she will stay general discovery but preserve the court's authority to allow narrowly tailored Lion Boulos discovery on fact questions material to immunity.
“Defendants are thus not entitled to a complete stay of discovery at the summary-judgment stage, if the Court finds limited discovery necessary to its determination of Murray's entitlement to qualified immunity.”
Cautions
Liberally construes pro se filings but will not 'invent, out of whole cloth, novel arguments'; a pro se plaintiff still must point to record evidence to defeat summary judgment.
“This does not mean, however, that a court will invent, out of whole cloth, novel arguments on behalf of a pro se plaintiff in the absence of meaningful, albeit imperfect, briefing.”
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 = 4 |
Granted: 2Denied: 1Moot / procedural: 1 | counts only |
| Motions to dismiss N = 4 |
Granted: 2Denied: 2 | counts only |
| Reconsideration N = 2 |
Denied: 2 | counts only |
| Partial summary judgment N = 1 |
Denied: 1 | counts only |
| Motion for entry of final judgment rule 54b N = 1 |
Granted: 1 | counts only |
| Motion to stay discovery 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.
“For the foregoing reasons, the Court GRANTS defendant's motion for summary judgment. Plaintiff's Section 1983 claims against Samuel Gore and Jose Ham are DISMISSED WITH PREJUDICE.”
“For the foregoing reasons, the Court DISMISSES plaintiff's claims for lack of subject-matter jurisdiction WITHOUT PREJUDICE.”
“For the foregoing reasons, plaintiffs' motion for partial summary judgment is DENIED as premature.”
“For the foregoing reasons, the Court OVERRULES plaintiff's objections, APPROVES and ADOPTS the Magistrate Judge's Report and Recommendation, DENIES defendant's motion to dismiss.”
“For the foregoing reasons, the motions for summary judgment are DENIED.”
“For the foregoing reasons, the motions for summary judgment are DENIED.”
“For the foregoing reasons, plaintiffs' motions for reconsideration are DENIED.”
“For the foregoing reasons, the Court DENIES plaintiff's motion to re-open the case and vacate the judgment.”
“the Court GRANTS defendants' motion to dismiss under Rule 12(b)(6) for failure to state a claim upon which relief can be granted.”
“Defendants' motion to dismiss is DENIED.”
“defendants' motion for summary judgment is GRANTED. Plaintiff's complaint is DISMISSED WITH PREJUDICE.”
“For these reasons, the Court GRANTS Chase's motion. A final judgment as to plaintiffs' claims against Chase will follow the entry of this Order.”
“the Court GRANTS IN PART and DENIES IN PART defendants' motion... The Court GRANTS defendants' request to stay all discovery... The Court DENIES defendants' request to stay discovery insofar as they seek to foreclose the Court's authority to permit narrowly tailored discovery pursuant to Lion Boulos and its progeny.”
Caseload & timing
From public federal docket records for this judge.
Median case duration in the sampled dockets: 310 days (N = 19).
Median motion-to-ruling time: 47 days (N = 5).
From the 11 enumerated 2021-2023 cases: a cluster of 'X v. United States' suits (FTCA/SS, thin/no docket entries), several Hurricane Ida first-party insurance cases (removed diversity), a marine limitation-of-liability matter, and personal-injury diversity cases. Nature-of-suit examples captured: Insurance, 340 Marine, P.I.: Other.