Margaret Merrell Miller Garnett
How Judge Garnett decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
On a Fourth Amendment suppression motion she will sustain a search on ANY independently sufficient exception and lean hard on inevitable discovery: even assuming a safety or inventory search exceeded its proper scope, she will admit the evidence if a later valid warrant would have produced it anyway. A defendant attacking one rationale (e.g. inventory-search policy limits) must defeat all of them -- including inevitable discovery through a federal warrant. The strength of the underlying case is irrelevant to the legal analysis.
“numerous exceptions to the warrant requirement (as well as the federal search warrant actually issued) preclude suppression of the Backpack and its contents in this case, whether through the discovery of the loaded magazine during a pre-transport safety search, the recovery of the remaining items in the course of an inventory search at the police station, or the inevitable discovery of all of the contents through the federal search warrant, even excising references to any items found or seen after the magazine, firearm, and/or silencer were found.”
She applies the categorical / modified-categorical approach to 18 U.S.C. 924(c)/(j) 'crime of violence' predicates rigorously and by the book, even when she thinks the doctrine is divorced from the real conduct and the result is counter-intuitive. A 924(c)/(j) count built on a predicate that is not categorically a 'crime of violence' (here, federal stalking under 2261A) will be dismissed regardless of how violent the alleged facts are. Defense counsel challenging a firearm count should frame the argument purely in categorical-approach / divisibility terms.
“The analysis contained in the balance of this Opinion may strike the average person -- and indeed many lawyers and judges -- as tortured and strange, and the result may seem contrary to our intuitions about the criminal law. But it represents the Court's committed effort to faithfully apply the dictates of the Supreme Court to the charges in this case. The law must be the Court's only concern.”
Procedural preferences
She actively polices Local Criminal Rule 23.1 (prejudicial extrajudicial statements) up the chain of command: when the defense flagged public statements by senior DOJ officials, she issued an order reminding the prosecution team that the Rule binds the highest levels of the Department, up to and including the Attorney General, and required a sworn response. Government counsel in high-profile matters before her should assume out-of-court statements will be scrutinized and that she will demand accountability from supervisors, not just line AUSAs.
“It appears from this letter that multiple employees at the Department of Justice may have violated Local Criminal Rule 23.1, and this Court's order of April 25, 2025 specifically identifying the strictures of this rule for counsel and directing the prosecution team to ensure that the highest levels of the Department of Justice, up to and including Attorney General Bondi, were aware of and understood they were bound by this Rule.”
Cautions
She manages motion practice tightly and front-loads oral argument only where it will help: in a heavily-briefed capital case she allotted a fixed 30 minutes per side for argument on the dispositive MTD but expressly declined argument on the remaining motions, finding the 'extensive and excellent briefing' sufficient. Expect crisp page limits (granted on request), firm staged deadlines, and argument reserved for the issues she wants to probe -- not a default.
“given the extensive and excellent briefing by both sides on the other pending motions and the issues presented by those motions, the Court does not believe oral argument on the remaining motions is necessary or would be helpful to the Court.”
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.
| Motions to dismiss N = 1 |
Granted: 1 | counts only |
| Motion to suppress 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 Defendant's motion to dismiss Counts Three and Four of the Indictment is GRANTED.”
“the motion to suppress the Backpack and its contents is DENIED.”
Caseload & timing
From public federal docket records for this judge.
Garnett was commissioned 2024-01-09, so her docket is young. The current docket page (2026) is dominated by a wave of alien-detainee habeas petitions (463), alongside a high-profile federal criminal docket and a mix of civil cases. Her 2024-2025 filings show ADA Title III accessibility suits, ERISA, securities, patent, copyright (Schedule A trademark/counterfeiting), PACA (agriculture), labor/management, and civil-rights matters -- with terminated civil cases overwhelmingly resolved by settlement, voluntary dismissal, or removal-to-arbitration rather than contested merits rulings. Reflects current assignments + a small terminated sample, NOT a tenure-wide caseload.