Karen L. Hayes
How Judge Hayes decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
Strong, repeated ERISA command: state-law benefit-denial and bad-faith-penalty claims are complete- or conflict-preempted and recast/dismissed; but she does NOT reflexively side with insurers -- she awarded an ERISA disability claimant his full LTD benefits on de novo review and denied the insurer's MSJ.
“the Motion for Summary Judgment [Doc. No. 24] filed by Plaintiff Alfred Mercer is ... otherwise GRANTED, and ... judgment is hereby entered in favor of Plaintiff Alfred Mercer ordering Defendant Life Insurance of North America to pay Plaintiff long term disability benefits”
On Medicare-recoupment and other administrative-review suits she applies jurisdictional channeling/exhaustion rigorously (42 U.S.C. 405(g)/(h)) -- dismissing premature claims WITHOUT prejudice rather than on the merits, but converting and dismissing the legally foreclosed ones WITH prejudice.
“it is recommended that Azar and Verma's motion be GRANTED-IN-PART and DENIED-IN-PART, and that Palmetto's motion be DENIED, as moot.”
Procedural preferences
At the pleading stage she favors a curative amendment over outright dismissal -- granting leave to amend (or staying for exhaustion) to let a fixable claim proceed, then granting the MTD only as to what truly cannot be cured.
“the undersigned granted Rollins leave to file an amended complaint within thirty days of the order.”
Cautions
In her own 636(c) consent cases she enforces Local Rule 56.1/56.2 strictly: a party opposing summary judgment must controvert the movant's statement of undisputed facts or those facts are deemed admitted. Failing to respond point-by-point can lose the motion.
“In the present case, CRU has only made a few objections to the statement of material facts presented by UNIC. Thus, all other facts in the statement submitted by UNIC are deemed admitted.”
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 = 4 |
Granted in part: 3Moot / procedural: 1 | counts only |
| Summary judgment N = 4 |
Granted: 1Granted in part: 1Denied: 2 | counts only |
| Motion for judgment on pleadings 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 reasons assigned below, it is recommended that Azar and Verma's motion be GRANTED-IN-PART and DENIED-IN-PART, and that Palmetto's motion be DENIED, as moot.”
“IT IS FURTHER ORDERED that the motion to dismiss [Doc. No. 28] filed by Palmetto GBA, L.L.C., is DENIED, as moot.”
“For reasons stated below, it is recommended that Defendants' motion to dismiss be GRANTED IN PART and DENIED IN PART.”
“IT IS ORDERED, ADJUDGED, AND DECREED that Defendants' Joint Mqtion for Partial Summary Judgment [Doc. No. 31] is hereby GRANTED ... Plaintiffs state law claims for penalties and detrimental reliance ... are hereby DISMISSED WITH PREJUDICE, as preempted.”
“Defendant Vantage Health Plan, Inc.'s 'Motion to Dismiss pursuant to Rule 12(b)(6) for Failure to Exhaust Administrative Remedies and in the Alternative, for Summary Judgment' [Doc. No. 11] ... GRANTED IN PART. Plaintiffs recast claim for unpaid benefits under ERISA Sec. 502(a)(1)(B) are hereby DISMISSED WITHOUT PREJUDICE.”
“Defendants Louisiana Corrugated Products, LLC, and U.S. Corrugated, Inc.'s Motion for Judgment on the Pleadings (converted to a motion for summary judgment) [Doc. No. 17] are each GRANTED IN PART. Plaintiffs recast claim for unpaid benefits under ERISA Sec. 502(a)(1)(B) are hereby DISMISSED WITHOUT PREJUDICE.”
“IT IS ORDERED that the Motion for Summary Judgment [Doc. No. 28] filed by Defendant Life Insurance Company of North America is hereby DENIED.”
“the Motion for Summary Judgment [Doc. No. 24] filed by Plaintiff Alfred Mercer is DENIED, insofar as it seeks to re-visit the standard of review to be applied in this case. ... [and] is otherwise GRANTED, and ... judgment is hereby entered in favor of Plaintiff Alfred Mercer ordering Defendant Life Insurance of North America to pay Plaintiff long term disability benefits retroactive to his alleged disability onset date.”
“it is recommended that the motion for summary judgment [doc. # 108] be DENIED.”
Caseload & timing
From public federal docket records for this judge.
Median case duration in the sampled dockets: 416 days (N = 15).