Stephen C. Riedlinger
Judge Riedlinger no longer hears cases. This profile is preserved as a historical record of how they ruled.
How Judge Riedlinger decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
Procedural preferences
He enforces the Prison Litigation Reform Act exhaustion requirement strictly, measuring it by whether the prisoner's grievance gave administrators a fair opportunity to address the specific problem later sued on -- a grievance that complained of different conduct does not exhaust the claims in the complaint, and the defense can win summary judgment on that ground even against an unopposed record.
“the primary purpose of a grievance is to alert prison officials to a problem, not to provide personal notice to a particular official that he may be sued. ... a grievance must provide administrators with a fair opportunity under the circumstances to address the problem that will later form the basis of the suit.”
On a motion to remand he holds the party seeking removal to a heavy burden of proving improper joinder, asking whether there is any reasonable basis to predict the plaintiff could recover against the in-state defendant under state law; where the undisputed evidence (here a deposition and the plaintiff's own expert report) shows none, he recommends denying remand and treats the non-diverse defendant as improperly joined.
“The party seeking removal based on improper joinder of an in-state party bears a heavy burden of proving that the joinder was improper. ... there is no reasonable basis for the district court to predict that the plaintiff might be able to recover against an in-state defendant.”
In prisoner suits he applies the 42 U.S.C. 1997e(e) physical-injury bar at the pleading stage: a complaint that alleges only mental or emotional harm, with no physical injury, cannot recover compensatory damages, and those claims are dismissed without leave to amend.
“A review of the allegations in the complaint showed that the plaintiff failed to allege that he sustained any physical injury as a result of the defendants' alleged actions. The failure to allege physical injury precludes recovery of compensatory damages for mental or emotional injuries.”
Signed rulings
A grounded sample of orders signed by this judge, with the verbatim dispositive language.
Section 1915(e) screening of a pro se prisoner complaint suing a private attorney for legal malpractice under 42 U.S.C. 1983. Recommended dismissal as frivolous because a private retained attorney does not act under color of state law and the plaintiff alleged no conspiracy with a state official. This screening recommendation did not resolve a party motion. Grounding quote: "It is the recommendation of the magistrate judge that the plaintiff's complaint be dismissed as frivolous pursuant to 28 U.S.C. 1915(e)(2)(B)(i)."
“It is the recommendation of the magistrate judge that the defendants' Motion To Dismiss be granted, dismissing the plaintiff's claims for compensatory damages pursuant to 42 U.S.C. 1997e and his claim that he was issued a false disciplinary report, and without leave to amend as to these claims. It is further recommended that the remainder of the plaintiff's claims be dismissed, unless within such time as fixed by the district judge the plaintiff files an amended complaint that allege specific facts which state a claim against each defendant upon which relief may be granted.”
“It is the recommendation of the magistrate judge that the defendant's Motion for Summary Judgment be granted, and this action be dismissed without prejudice to any state law claim.”
“It is the recommendation of the magistrate judge that the plaintiff's motion for summary judgment be denied, that the defendant's motion for summary judgment be granted, and this action be dismissed.”
“It is the recommendation of the magistrate judgment that the Motion to Remand filed by plaintiff Yolanda Stills be denied.”
Caseload & timing
From public federal docket records for this judge.
His enumerated assigned docket reflects a consent and duty magistrate's mix: Social Security disability and SSI appeals decided on the administrative record, diversity personal-injury and insurance suits, federal-question civil-rights employment cases, commercial and trade-secret disputes, and criminal-duty matters. Across 15 terminated consent cases from this slice, the time from filing to termination ran from about 259 days to roughly 1,572 days (median around 443 days), the longest being a multi-year commercial case and the shortest settled personal-injury and Social Security matters. The substantive referral work for which he wrote reports and recommendations sits on dockets assigned to the district judges and is only partly captured by the assigned-judge field.
A historical record
Judge Riedlinger 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.