William John Martini
How Judge Martini decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
Qualified immunity protects 'all but the plainly incompetent or those who knowingly violate the law' - but an officer who allegedly fabricates grand-jury testimony to manufacture probable cause forfeits it: that claim survives a 12(b)(6) motion while the same claims against officers pled only in conclusory terms are dismissed. Prosecutorial absolute immunity covers judicial-phase acts (presenting evidence, charging decisions) but not investigative functions or pre-arrest legal advice.
“These claims will remain against Reifler because if he did testify falsely and concoct facts to establish probable cause for Plaintiffs' arrest that led to their indictment, he cannot then claim qualified immunity.”
Procedural preferences
Default judgment is strongly disfavored. Martini denies a first-round vacate-default motion without prejudice when the defendant fails to attach an Answer or articulate a meritorious defense, but readily vacates the default (and denies the plaintiff's default-judgment cross-motion) once the defendant cures by filing an Answer plus a well-stated meritorious defense within the set window.
“Within 30 days of the order, Defendants filed an Answer and a new motion to vacate default. This motion contains meritorious defenses. ... Finding good cause to vacate default”
On a motion to compel arbitration he applies the Third Circuit's Guidotti framework: where arbitrability is apparent on the face of the complaint he uses a 12(b)(6) standard, but where the complaint neither references nor attaches the agreement, he denies the motion without prejudice and orders limited discovery on whether a valid agreement to arbitrate exists, to be decided on renewal under a Rule 56 standard.
“Because the Complaint does not establish on its face that the parties agreed to arbitrate, the Court cannot decide the present motion without first ordering limited discovery as to the question of arbitrability.”
Cautions
Section 1983 / civil-rights complaints must plead each individual defendant's role with particularity: blanket allegations that a group of officers acted 'because plaintiffs were African-American' or that a supervisor 'failed to adopt policies' are conclusory under Iqbal and dismissed (without prejudice for the curable ones). The NJCRA is coextensive with Section 1983, and there is no implied private right of action under Section 1981 against state actors.
“the allegations lack particularity as to each individual Defendant's role. Plaintiffs must assert plausibly why there lacked probable cause for arrest and how each individual Defendant acted maliciously”
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 = 1 |
Granted: 1 | counts only |
| Motions to dismiss N = 1 |
Granted in part: 1 | counts only |
| Motion to vacate default N = 1 |
Granted: 1 | counts only |
| Default judgment N = 1 |
Denied: 1 | counts only |
| Motion to compel arbitration N = 1 |
Moot / procedural: 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 reasons stated above, UBS's motion for summary judgment, ECF No. 111, is GRANTED.”
“the State Defendants' motion to dismiss is GRANTED in part in that the NJCRA and Section 1981 claims ... are DISMISSED WITH PREJUDICE ... As to Reifler, the motion to dismiss is GRANTED in part ... but it is DENIED in part as to dismissing the remaining Section 1983 and state malicious prosecution claims”
“Finding good cause to vacate default ... ORDERED that Defendants' motion to vacate default is hereby GRANTED”
“ORDERED that Plaintiff's motion to enter default judgment is hereby DENIED.”
“the motion to compel arbitration is DENIED WITHOUT PREJUDICE. The parties are to engage in discovery on the narrow issue of whether an agreement to arbitrate exists.”