Janet Theresa Neff
How Judge Neff rules, drawn from 16 signed orders. Every observation links to the order it came from.
Judge Neff no longer sits on this court. This profile is preserved as a historical record of how they ruled here.
About Judge Neff
Janet T. Neff joined the United States District Court for the Western District of Michigan after appointment by President George W. Bush. She assumed senior status in March 2021. The court reassigned her pending cases in October 2024 after she took inactive senior status.
How Judge Neff decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
In an employment-discrimination case built on a workforce-reduction termination, she required the plaintiff to identify a truly comparable co-worker, same duties, skills, and responsibilities, not merely a shared supervisor or work area, before letting a discrimination claim reach a jury.
“Considering the job titles, responsibilities, requirements, and performance of the Warehouse Department at Defendant's Albion facility, the Court agrees with Defendant and finds Plaintiff failed to show the fourth element of her prima facie case.”
In Select Specialty Hospital v. National City Bank Health & Welfare Plan, Neff held that the plan's unambiguous anti-assignment clause barred the treating hospital from suing for benefits as an assignee.
“The anti-assignment provision is this case is both unambiguous and enforceable. This Court is not persuaded that the absence of a reference to 'health care providers' in the anti-assignment clause at bar renders the clause ambiguous.”
On a challenge to diversity jurisdiction, she counted a contractual attorney's-fee provision toward the amount in controversy, following the majority rule that contract-based fees (not just statutory fees) count: a plaintiff resisting dismissal can lean on that provision to clear the jurisdictional threshold.
“R & D contends that Williamson constitutes binding authority for the proposition that attorneys fees provided by contract are included in the amount in controversy... Murk cites no authority or persuasive reasoning to reject this majority rule.”
Procedural preferences
In McNees v. Torrey, she sustained the plaintiff's objections and rejected a magistrate judge's recommendation because it had not considered his timely response to the defendant's motion.
“Plaintiff's objections have merit inasmuch as the Magistrate Judge did not consider his response in her Report and Recommendation on Defendant Torrey's motion. Accordingly, this Court will grant the objections and reject the Report and Recommendation.”
In Kaydon v. Geddings, Neff remanded the case because removal was untimely. Having found no removal jurisdiction, she did not reach the separate personal-jurisdiction dispute.
“Accordingly, this Court first turns to plaintiff's Motion to Remand... Having determined that this Court does not have removal jurisdiction over this matter, it is unnecessary for this Court to also resolve whether this Court lacks personal jurisdiction over defendant.”
Cautions
In United States v. Murphy, she denied compassionate release because the defendant had not shown an unusual medical risk from COVID-19 that made the pandemic an extraordinary and compelling reason for release.
“The pandemic itself is not considered an extraordinary and compelling reason 'absent extenuating circumstances.' Defendant has not shown any extenuating circumstances because there is no evidence that he suffers any unusual medical risk or vulnerability to the virus.”
In Hafke v. Rossdale Group, LLC, she found the plaintiff's Michigan commercial-email claims preempted by CAN-SPAM because the state-law allegations involved technical header and opt-out violations rather than materially false or deceptive conduct.
“Michigan's 'Unsolicited Commercial E-Mail Protection Act' differs markedly from the California statute... none of the terms of the Michigan Act explicitly addresses claims of falsity or deception. The technical violations regarding header, sender, and opt-out information that Plaintiff alleges as violations of the Michigan statute are not allegations of materially deceptive actions.”
Signed rulings
A grounded sample of orders signed by this judge, with the verbatim dispositive language.
“IT IS FURTHER ORDERED that Defendant Jennett’s Motion to dismiss (ECF No. 17) is DENIED for the reasons set forth in the Report and Recommendation.”
“IT IS FURTHER ORDERED that Defendants’ motions to dismiss (ECF Nos. 8, 20, & 25) are GRANTED.”
“IT IS FURTHER ORDERED that Defendant Progressive’s Motion for More Definite Statement (ECF No. 5) is DENIED without prejudice.”
“For the foregoing reasons, this Court grants defendants summary judgment of plaintiff’s complaint.”
“IT IS FURTHER ORDERED that the Motions for Summary Judgment (ECF No. 16 & 29) are GRANTED.”
“IT IS HEREBY ORDERED that Defendant’s Motion for Summary Judgment (ECF No. 93) is GRANTED.”
“IT IS FURTHER ORDERED that Plaintiff’s Counter-Motion for Summary Judgment (ECF No. 95) is DENIED.”
“IT IS FURTHER ORDERED that Defendants’ Motion for Summary Judgment (ECF No. 57) is GRANTED. IT IS FURTHER ORDERED that Defendant’s Motion for Summary Judgment (ECF No. 82) is GRANTED.”
“For the foregoing reasons, the Motion to Dismiss is DENIED.”
“The Court grants plaintiff’s Motion to Remand (Dkt 14) and consequently declines to decide the merits of defendant’s ‘Motion to Set Aside Default Judgment and Dismiss for Lack of Personal Jurisdiction’ (Dkt 33).”
“Plaintiff’s motion to remand (Dkt 4) is denied on the grounds that this Court has federal question jurisdiction under CAN-SPAM, which expressly preempts Plaintiff’s claims.”
“IT IS FURTHER ORDERED that the petition for habeas corpus relief (Dkt 1) is DENIED for the reasons stated in the Report and Recommendation.”
“IT IS FURTHER ORDERED that the petition for habeas corpus relief (ECF No. 1) is DENIED for the reasons stated in the Report and Recommendation.”
“IT IS HEREBY ORDERED that Defendant’s Motion for Compassionate Release (ECF No. 40) and Motion to Appoint Counsel (ECF No. 41) are DENIED.”
Caseload & timing
From public federal docket records for this judge.
- Her 2018 filing-year caseload was a mix of prisoner civil-rights and habeas matters referred to a magistrate judge, employment and FLSA wage cases, consumer credit-reporting suits, a state-brought RICO case against opioid manufacturers (transferred to the national opiate multidistrict litigation within weeks), an ADA/transit case, and a state environmental enforcement action over PFAS groundwater contamination.
- Her 2021-2024 sample is weighted toward Section 2255 motions to vacate a federal sentence and criminal cases, consistent with a senior judge's reduced but still-active docket in her final years before taking inactive status.
Pending matters in the official report
Judge Neff was last listed in the Civil Justice Reform Act report as of September 30, 2024.
| Motions pending more than six months | 11 |
| Bench trials submitted more than six months | 0 |
| Bankruptcy appeals pending more than six months | 0 |
| Social Security appeals pending more than six months | 0 |
| Civil cases pending more than three years | 7 |
| Report | Motions over six months | Cases over three years |
|---|---|---|
| Sep 2024 | 11 | 7 |
| Mar 2024 | 17 | 10 |
| Sep 2023 | 17 | 9 |
| Mar 2023 | 10 | 5 |
| Sep 2022 | 12 | 7 |
| Mar 2022 | 21 | 7 |
| Sep 2021 | 17 | 6 |
| Mar 2021 | 31 | 8 |
| Sep 2020 | 18 | 6 |
A snapshot on that date: matters listed may since have been decided or reassigned. A motion referred to a magistrate judge is counted for both judges. Motions in multidistrict litigation, section 2255 cases and Social Security appeals are not counted, and a very large three-year count is generally a multidistrict docket. Source: Appendix A of the report (PDF); about the report.
A historical record
Judge Neff no longer sits on this court. This profile stays available as a record of how they ruled here. If you're preparing for a matter, start from the court's current bench.