Joan Marie Azrack
How Judge Azrack decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
Strictly construes the FTCA's jurisdictional presentment requirement and the waiver of sovereign immunity against the claimant: a vague SF-95 injury description is inadequate, and the common-law mailbox rule does not apply, so a plaintiff must prove the agency actually received supporting records before suit.
“the mailbox rule is inapplicable to claims brought under the FTCA, and that therefore the mere mailing of a notice of claim does not satisfy the FTCA's presentment requirement. The statute and corresponding regulation make clear that actual receipt is required”
Treats substantive due process as unavailable where a more specific constitutional provision governs the same conduct -- a 'backup' Fourteenth Amendment theory will not survive a motion to dismiss alongside First/Fourth Amendment claims.
“a substantive due process analysis is inappropriate where a more specific constitutional standard is directly applicable.”
On summary judgment she declines to resolve genuinely fact-specific questions on the papers and sends them to a factfinder, even while granting the motion on the legally clear claim in the same order.
“where an accommodation is made, whether that accommodation is reasonable is a fact-specific question that often must be resolved by a factfinder.”
Reads insurance-policy terms by their ordinary meaning and refuses to stretch 'bodily injury' to cover bare physical contact or confinement absent an actual physical injury, defeating a duty-to-defend theory.
“The Court does not agree that unwanted physical contact or physical confinement, without more, constitutes a “bodily injury.” The Court also concludes that the term “bodily injury” is not ambiguous on this point.”
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 = 8 |
Granted: 5Granted in part: 1Denied: 2 | counts only |
| Motions to dismiss N = 2 |
Granted: 2 | counts only |
| Default judgment N = 2 |
Granted: 1Granted 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.
“Defendant's motion for summary judgment is GRANTED and this case is DISMISSED.”
“Defendants' partial motion to dismiss is therefore GRANTED in its entirety.”
“the defendant's motion to dismiss the plaintiff's amended complaint is granted and the plaintiff's amended complaint is dismissed with prejudice.”
“(2) Defendant's motion for summary judgment as to Plaintiff's ADA reasonable accommodation claim is DENIED; ... and (4) Defendant's motion for summary judgment as to Plaintiff's constructive discharge claim is GRANTED.”
“(1) Plaintiff's motion for summary judgment as to her ADA reasonable accommodation claim is DENIED; ... (3) Plaintiff's motion for summary judgment as to her constructive discharge claim is DENIED”
“Defendant's motion for summary judgment is granted and plaintiff's motion for summary judgment is denied.”
“Defendant's motion for summary judgment is granted and plaintiff's motion for summary judgment is denied.”
“Plaintiff's motion for summary judgment against Habeeb is granted.”
“The motion for default judgment is granted as to Sankar but denied as to Slomins Inc., with leave to renew.”
“Accordingly, I grant defendants' motion for summary judgment.”
“plaintiff's motion is GRANTED and plaintiff is awarded a default judgment against defendants in the amount of $148,336.89.”
“The Court grants defendant's motion for summary judgment.”
Caseload & timing
From public federal docket records for this judge.
Median case duration in the sampled dockets: 549 days (N = 6).
Senior E.D.N.Y. district judge in Central Islip (Long Island; suffix 'JMA'), still actively assigned despite senior status (Dec. 2024); 2026 assignments confirm she continues drawing new criminal and civil cases. Sampled district dockets are dominated by (a) a substantial criminal docket (e.g. United States v. Henriquez 2:20-cr-00577, United States v. Novis 2:20-cr-00335, United States v. Roth 2:20-cr-00481, United States v. Barakat 2:18-cr-00292, United States v. Cole 1:26-cr-00156) and (b) a broad civil mix: mortgage foreclosures (Freedom Mortgage v. Habeeb, U.S. Bank v. Whittle), FLSA/wage labor (O'Hara v. Mount Sinai, Pumayalli Julcarima v. Wenger), ADA Title III access (Hogan v. McDonald's), Social Security appeals (Huynh v. Commissioner), consumer credit (Gorman v. Retrieval-Masters), FTCA personal injury (Moudis v. United States), and P.I./mass-tort (Doe v. Uber). Mix is qualitative this build (case-level metadata only).