Laurie Jill Michelson
How Judge Michelson decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
Procedural preferences
On a Rule 12(b)(6) motion she confines review strictly to the four corners of the complaint: a plaintiff cannot rehabilitate a conclusory complaint through arguments or new allegations raised in a response brief. Plead the facts in the complaint itself.
“A plaintiff’s response brief to a motion to dismiss cannot cure a deficient complaint. ... it is black-letter law that ... a court evaluating ... a motion to dismiss[] must focus only on the allegations in the pleadings.”
Will not entertain a premature summary-judgment motion: pre-discovery MSJs are disfavored and pre-service MSJs are flatly premature, dismissed without prejudice to refiling at the appropriate time. Wait for service and discovery.
“Shaik’s motion is premature. The parties have not yet had a scheduling conference with the Court, let alone engaged in any discovery. ... Pre-discovery motions for summary judgment are generally disfavored. ... And pre-service motions certainly are premature.”
On unobjected-to R&Rs she applies the Sixth Circuit's procedural-default rule (Walters / Thomas v. Arn): failure to file specific objections waives review even at the district-court level. Object specifically and on time to preserve any review.
“The Court finds that the parties’ failure to object is a procedural default, waiving review of the Magistrate Judge’s findings by this Court. ... a party shall file objections with the district court or else waive right to appeal.”
Cautions
Construes pro se filings liberally but enforces basic pleading requirements equally against represented and self-represented plaintiffs -- liberal construction is 'not boundless'.
“while a pro se litigant’s complaint must be construed “liberally,” ... the Court’s leniency is “not boundless.” ... Basic pleading requirements “apply to self-represented and counseled plaintiffs alike.””
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 = 5 |
Granted: 2Denied: 2Moot / procedural: 1 | counts only |
| Motions to dismiss N = 2 |
Granted: 2 | counts only |
| Motion for reconsideration N = 1 |
Granted in part: 1 | counts only |
| Motion to alter or amend judgment N = 1 |
Denied: 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.
“this Court DENIES Plaintiff’s motion for summary judgment (R. 14) and GRANTS Defendant’s motion for summary judgment (R. 16).”
“this Court DENIES Plaintiff’s motion for summary judgment (R. 14) and GRANTS Defendant’s motion for summary judgment (R. 16).”
“the Commissioner’s motion for summary judgment (R. 13) is GRANTED and the Plaintiff’s motion (R. 12) is DENIED.”
“the Commissioner’s motion for summary judgment (R. 13) is GRANTED and the Plaintiff’s motion (R. 12) is DENIED.”
“Hire Counsel’s motion to dismiss (ECF No. 13) is GRANTED. Counts I, III, and IV are DISMISSED WITHOUT PREJUDICE to refiling if administrative remedies are timely and properly exhausted. Counts V and VI are DISMISSED WITHOUT PREJUDICE to refiling in state court. Count II is DISMISSED WITH PREJUDICE.”
“the Court DISMISSES Shaik’s Motion for Summary Judgment (ECF No. 23) without prejudice to refiling at the appropriate time.”
“Trans Union’s motion to dismiss is GRANTED and the case is DISMISSED WITHOUT PREJUDICE.”
“Queen’s motion for reconsideration is GRANTED IN PART and the Court VACATES the portion of its opinion that concluded it lacked jurisdiction over the motion.”
“The Court reiterates that holding here, and denies Queen’s motion to alter or amend the judgment on the merits.”
Caseload & timing
From public federal docket records for this judge.
Nature-of-suit mix observed across her enumeration + the GovInfo civil dockets. Michelson carries a notable share of qui tam / False Claims Act cases plus consumer-credit (FCRA), employment-discrimination, civil-rights, Social Security, criminal, and some duty-docket search/seizure-warrant matters (not counted as merits cases).