Elizabeth C. Coombe
How Judge Coombe rules, drawn from 10 signed orders. Every observation links to the order it came from.
How Judge Coombe decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
Grants a defendant's motion to dismiss where the complaint fails to state a claim, commonly granting the plaintiff leave to amend within a set period.
“Defendant's motion to dismiss, Dkt. No. 10, is GRANTED; it is further ORDERED that Plaintiff is granted leave to amend ... any amended complaint must be filed within 30 days”
In disputes involving federal loan instruments, she applies the federal rule that the United States is not subject to state limitation periods and gives effect to contract language selecting federal law. A state-law limitations theory will not quiet title against a federal mortgage where both doctrines foreclose it.
“the federal government is 'never time barred from bringing a foreclosure action because of a statute of limitations.'”
When immigration detention was unlawful and promised custody hearings remained unscheduled, she ordered individualized bond hearings within seven days and placed a clear-and-convincing burden on the government to prove dangerousness or flight risk.
“the appropriate relief is a prompt bond hearing”
Procedural preferences
Adopts the assigned magistrate judge's Report-Recommendation in its entirety, including on summary judgment where the plaintiff files no opposition.
“the Court adopts the Report-Recommendation in its entirety ... Defendant's Motion for Summary Judgment, Dkt. No. 30, is GRANTED; ... Plaintiff's Complaint, Dkt. No. 1, is DISMISSED”
Cautions
Enforces litigation obligations: dismisses claims with prejudice under Rule 41(b) for failure to prosecute (e.g., refusing to appear for deposition).
“the Defendant's motion to dismiss Named Plaintiff Larry Balcolm's claims pursuant to Rule 41(b), Dkt. No. 43, is GRANTED, and Named Plaintiff Larry Balcolm's claims are DISMISSED with prejudice”
Reconsideration of a remand faces both a jurisdictional bar and the ordinary strict standard. Even when she addresses the merits alternatively, a movant must identify changed law, new evidence, clear error, or manifest injustice rather than repeat removal arguments.
“Even if the remand order were reviewable, however, Hamza has not identified a change of law, new evidence, or error that would be a basis for reconsideration.”
Signed rulings
A grounded sample of orders signed by this judge, with the verbatim dispositive language.
“Defendants' motion to dismiss under Rules 12(b)(1) and 12(b)(6), Dkt. No. 23, is GRANTED in part and DENIED in part ... GRANTED as to Plaintiff's Fourteenth Amendment due process claim ... this claim is DISMISSED without prejudice ... in all other respects DENIED”
“Defendant's motion to dismiss, Dkt. No. 10, is GRANTED; it is further ORDERED that Plaintiff is granted leave to amend ... any amended complaint must be filed within 30 days”
“the Defendant's motion to dismiss Named Plaintiff Larry Balcolm's claims pursuant to Rule 41(b), Dkt. No. 43, is GRANTED, and Named Plaintiff Larry Balcolm's claims are DISMISSED with prejudice”
“Plaintiff's motion, Dkt. No. 18, is DENIED; it is further ORDERED that unless Plaintiff amends its complaint within 30 days, this action is to be dismissed without prejudice”
“Magistrate Judge Lovric's Report-Recommendation, Dkt. No. 81, is ADOPTED in its entirety; and it is further ORDERED that Defendant Cayuga County's motion to dismiss, Dkt. No. 62, is DENIED”
“the Court adopts the Report-Recommendation in its entirety ... Defendant's Motion for Summary Judgment, Dkt. No. 30, is GRANTED; ... Plaintiff's Complaint, Dkt. No. 1, is DISMISSED”
“ORDERED that the Motion for Reconsideration and to Vacate Summary Remand is denied.”
“ORDERED that Defendant's motion to dismiss, Dkt. No. 15, is GRANTED and the Complaint is DISMISSED”
On clear-error review, the court adopted an unobjected recommendation to dismiss a pro se FOIL case for lack of subject-matter jurisdiction. The order states: 'Plaintiff's Complaint, Dkt. No. 1, is DISMISSED without prejudice but without leave to amend.' No party motion was adjudicated, so the order is excluded from motion statistics.
“ORDERED that the Petitions are GRANTED solely to the extent that the Court orders Respondents to provide Petitioners with individualized bond hearings before an immigration judge within seven days of this order, at which the government will bear the burden of proving, by clear and convincing evidence, that Petitioner is a danger to the community or a flight risk”
“ORDERED that Petitioners’ requests for reasonable attorney’s fees and costs under the Equal Access to Justice Act are DENIED WITH LEAVE TO RENEW because they are premature”
Caseload & timing
From public federal docket records for this judge.
Median motion-to-ruling time: 170 days (N = 9).
The reviewed June 2024 through March 2025 filing window spans civil-rights, employment, education, Social Security, tax-recovery, mortgage-foreclosure, and criminal matters. The cases assigned after Coombe's December 2024 commission reflect a broad general-civil district docket, but most remain pending. The few early civil terminations support only illustrative duration figures.
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