Natasha Clarise Merle
How Judge Merle decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
She is a strong believer in the jury's province on summary judgment. Where the record presents genuine disputes of material fact, she will deny cross-motions for summary judgment and send the case to trial -- and she expressly rejects the argument that fact questions implicating public safety are too important for a civil jury. A defendant cannot win SJ by invoking deference to its own safety judgment when the underlying facts are reasonably disputed.
“To state that factual issues implicating public safety are beyond the reach of a civil jury is to ignore the very function of that body whose 'purpose' is to 'assure a fair and equitable resolution of factual issues.'”
On a preliminary injunction she treats irreparable harm as the threshold she will not relax. Speculative or contingent harm (here, that an administrative finding 'might' later be given preclusive effect) is not enough, and a harm that money damages can remedy (loss of employment) does not qualify absent something more. She will deny without reaching likelihood of success once irreparable harm fails.
“Irreparable harm 'is the single most important prerequisite' for injunctive relief, and 'in the absence of a showing of irreparable harm, a motion for a preliminary injunction should be denied.'”
On emergency injunctive relief her irreparable-harm gate cuts both ways: where the harm is concrete and not remediable by money damages and the merits are strong, she grants. In an APA challenge to ICE's termination of an F-1 student's SEVIS record she found a likelihood of success and irreparable harm, granted a TRO, and waived the Rule 65(c) bond -- the mirror image of her Williams PI denial where the asserted harm was speculative and reparable in damages.
“plaintiffs have shown by a preponderance of the evidence a likelihood of success on the merits of their claim pursuant to the Administrative Procedure Act ... that plaintiffs will likely suffer irreparable harm which cannot be remedied by money damages”
Procedural preferences
She holds parties to the summary-judgment record and to the four corners of the pleadings. New factual theories or damages claims raised for the first time in a declaration or in opposition briefing will not be considered, and a request for relief 'not properly before the Court on a motion to dismiss' (raised only in the briefs) is disregarded. Plead and develop your theory in the complaint and your Rule 56 papers, not in reply.
“the Court 'should not on summary judgment consider factual allegations and legal theories not raised in the complaint.'”
She prunes duplicative claims at the pleading stage. On a Rule 12(c) motion she dismissed unjust-enrichment and declaratory-judgment claims as duplicative of the plaintiff's fraud cause of action -- a declaratory-judgment claim that merely restates the relief available under another count is redundant and will be dismissed. Do not plead quasi-contract or declaratory counts that simply mirror your primary claim.
“The relief plaintiff seeks under his declaratory judgment claim ... is plainly duplicative of its cause of action for fraud.”
On a Rule 12 motion she is a generous gatekeeper for fact-intensive theories: scope-of-employment/vicarious liability, the existence of a fiduciary duty, and entitlement to specific performance are all treated as fact-dependent questions usually unsuited to resolution at the pleading stage, so she lets them proceed to discovery. Defendants moving to dismiss such theories as a matter of law tend to lose (3 of her 5 MTD rulings are granted-in-part, 2 denied outright, 0 full grants in this sample).
“Whether a fiduciary duty exists is necessarily fact-specific to the particular case ... Therefore, a claim alleging the existence of a fiduciary duty usually is not subject to dismissal under Rule 12(b)(6).”
Reconsideration is a hard sell. She treats Local Rule 6.3 motions as an extraordinary remedy granted only on a controlling-law change, new evidence, or clear error -- not on a party's disagreement, and not as a vehicle to rehash rejected arguments. She also polices litigants who cite summary-judgment-stage authority against a motion-to-dismiss ruling. Both reconsideration motions in this sample were denied.
“A motion for reconsideration is an extraordinary remedy to be employed sparingly and can be granted only upon a showing of exceptional circumstances.”
Cautions
On unopposed or default-adjacent dispositions she still reviews the record rather than rubber-stamping: she adopted the magistrate's foreclosure R&R only after independently satisfying herself there was no clear error and that the claimed damages and costs were adequately supported and reasonable. Submit a complete, well-supported damages showing even when the motion is unopposed.
“Having reviewed the record, I find that plaintiff has satisfied the requirements for a judgment of foreclosure ... Plaintiff has submitted adequate evidence to support its claimed damages, and its claimed costs and disbursements of $1,817.29 are reasonable.”
She enforces prosecution and counsel-diligence duties strictly. She will dismiss under Rule 41(b) after repeated unanswered show-cause orders, and she will not vacate that dismissal under Rule 60(b)/59(e) for attorney neglect: an attorney who initiated the suit must monitor the docket even after removal and absent withdrawal, and a technical email/spam failure plus genuine personal hardship did not excuse a four-month disregard of the case. Gross negligence of counsel is not a basis for Rule 60(b)(6) relief.
“Even if a technical problem prevented Seddio from seeing electronic notifications that were sent to his email, Seddio had an obligation to monitor the docket sheet to inform [himself] of the entry of orders.”
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 = 6 |
Granted: 2Granted in part: 1Denied: 3 | counts only |
| Motions to dismiss N = 5 |
Granted in part: 3Denied: 2 | counts only |
| Motion for reconsideration N = 2 |
Denied: 2 | counts only |
| Default judgment N = 2 |
Granted in part: 2 | counts only |
| Preliminary injunction N = 2 |
Denied: 1Moot / procedural: 1 | counts only |
| Motion for judgment on pleadings N = 1 |
Granted in part: 1 | counts only |
| Motion for judgment of foreclosure N = 1 |
Granted: 1 | counts only |
| Motion in limine N = 1 |
Denied: 1 | counts only |
| Motion for temporary restraining order N = 1 |
Granted: 1 | counts only |
| Motion for relief from judgment N = 1 |
Denied: 1 | counts only |
| Notice of removal 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.
“the Midvale Motion is DENIED, and the Cross Motions are GRANTED in part, DENIED in part.”
“the defendants' Cross Motions are GRANTED in part, DENIED in part; ... the Court DECLARES that Midvale has a duty to defend Arevalos and D&G with respect to the action captioned Victor Siguenza Zuniga v. 625 Halsey LLC, et al.”
“defendant Lowe's Home Centers, LLC's motion for summary judgment is GRANTED. Plaintiffs' claims against Lowe's are dismissed.”
“defendants' motion for judgment on the pleadings is GRANTED in part, and DENIED in part. Plaintiff's claims for unjust enrichment and declaratory judgment are dismissed.”
“the Court GRANTS defendant's motion for summary judgment in its entirety. The Clerk of Court shall enter judgment accordingly and close the case.”
“Having found no clear error, I therefore adopt the Report and Recommendations, in their entirety, as the opinion of the Court pursuant to 28 U.S.C. § 636(b)(1). Accordingly, the Clerk shall enter judgment (1) ordering the foreclosure and sale of 67 Harriman Ave, Hempstead, NY 11550 ... (4) directing that the plaintiff receive $618,291.92”
“defendant Lewis's motion for preliminary injunction is DENIED.”
“For the reasons stated above, the cross-motions for summary judgment are DENIED.”
“For the reasons stated above, the cross-motions for summary judgment are DENIED.”
“defendant's motions in limine to (1) dismiss plaintiffs' request for punitive damages; (2) preclude evidence or testimony regarding defendant's financial size or condition; and (3) preclude testimony regarding an alleged power outage at the New York City dispatch center on March 21, 2024 are DENIED.”
Her own signed MEMORANDUM & ORDER screening a pro se 42 U.S.C. 1983 complaint under 28 U.S.C. 1915. Ruling on no party motion -> recorded as an order read, excluded from motion stats. Dismissed claims against the state-court judges (judicial immunity), the court clerk, and the defense attorneys (not state actors), and allowed the excessive-force/false-arrest claims against the individual police officers to proceed. Grounding quote: 'Plaintiff's claims against Kings County Criminal Court Judges John Hecht, Dineen Riviezzo, and Phyliss Chu, Chief Court Clerk Brian M. McAllister, and attorneys Mario Romano and Jeremy Saland are dismissed. ... [the police-officer defendants] may proceed.' Referred to Magistrate Judge Seth D. Eichenholtz.
“defendant's motion to dismiss is GRANTED in part, DENIED in part. Plaintiff's claims for negligent and intentional infliction of emotional distress are DISMISSED without prejudice.”
“For the reasons set forth above, defendant's motion for reconsideration is DENIED.”
“defendant's motion to dismiss is granted in part, denied in part. Plaintiff's Title VII discrimination claim is hereby dismissed.”
Caseload & timing
From public federal docket records for this judge.
Routine ADA/FLSA/contract matters terminate in roughly 5-10 months; the qui tam ran ~4.3 years. Many quick terminations are voluntary dismissals or 28 U.S.C. 1915 screening dismissals (e.g. Rubinov), not merits rulings. Mix is a typical Brooklyn/Long Island civil intake plus a 2026 alien-detainee habeas uptick.