Sarah Netburn

How Judge Netburn rules, drawn from 4 signed orders. Every observation links to the order it came from.

Court
United States District Court for the Southern District of New York
Position
magistrate
Education
Brown University (B.A.); University of California, Los Angeles School of Law (J.D.)
Signed orders read
4

How Judge Netburn decides

Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.

What persuades

In consent ERISA cases, Netburn applies deferential arbitrary-and-capricious review and has upheld the plan administrator's benefit determination.

“The defendants' motion for summary judgment is granted, and the plaintiffs motion is denied.”

In immigration habeas, grants the petition and orders a bond hearing where the statute's plain language does not authorize prolonged mandatory detention without one.

“Because I find that the plain language of the statute prohibits the extraordinary restrictions on Rodriguez's liberty sought by the government, Rodriguez's petition is GRANTED. The government is ordered to provide Rodriguez with a bond hearing, pursuant to Section 236(a), no later than ten days from the date of this Order.”

Procedural preferences

On multi-party summary judgment, Netburn rules separately by party and claim, enforcing a liability release against ordinary negligence while preserving gross-negligence claims and dismissing parties that owed no duty.

“NYCBS's motion for summary judgment is GRANTED in part; because the Court finds that the Release Agreement is enforceable as to NYCBS, Corwin's common-law negligence claims are barred, but he may still maintain gross negligence claims.”

On discovery motions to compel, conducts in camera review and a Kovel agent-of-attorney analysis before granting relief in part.

“For the reasons stated below, the plaintiffs' motion to compel is granted in part and denied in part.”

Signed rulings

A grounded sample of orders signed by this judge, with the verbatim dispositive language.

Jones v. PepsiCo, Inc.
185 F. Supp. 3d 437 · 2016-05-06
Summary judgment (defendant) Granted

“The defendants' motion for summary judgment is granted, and the plaintiffs motion is denied.”

Summary judgment (plaintiff) Denied
Corwin v. NYC Bike Share, LLC
238 F. Supp. 3d 475 · 2017-03-01
Summary judgment (defendant) Denied

“The City's motion for summary judgment is DENIED; as stated above, the Release Agreement is ineffective to waive Corwin's claims at to the City, and the City has not demonstrated its entitlement to judgment as a matter of law on qualified immunity, notice, or other grounds.”

Summary judgment (defendant) Granted in part

“NYCBS's motion for summary judgment is GRANTED in part; because the Court finds that the Release Agreement is enforceable as to NYCBS, Corwin's common-law negligence claims are barred, but he may still maintain gross negligence claims.”

Summary judgment (defendant) Granted

“APD's motion for summary judgment is GRANTED because APD and APDNY did not owe any duty to Corwin. Accordingly, APD and APDNY are dismissed from this case.”

Summary judgment (defendant) Denied

“Metro Express and Sealcoat's motions for summary judgment are DENIED because a genuine dispute of material fact exists as to whether they owed Corwin a duty of care under applicable New York law.”

Summary judgment (plaintiff) Granted in part

“For the following reasons, the cross-motions for summary judgment are GRANTED in part and DENIED in part. Corwin's motion to dismiss defendants' affirmative defenses relying on the Release Agreement is DENIED as to NYCBS ... is GRANTED as to the City ... Corwin's motion to dismiss defendants' affirmative defenses relating to his non-use of a helmet is GRANTED in part.”

Rodriguez v. Shanahan
84 F. Supp. 3d 251 · 2015-01-30
Petition for habeas corpus (petitioner) Granted

“Because I find that the plain language of the statute prohibits the extraordinary restrictions on Rodriguez's liberty sought by the government, Rodriguez's petition is GRANTED. The government is ordered to provide Rodriguez with a bond hearing, pursuant to Section 236(a), no later than ten days from the date of this Order.”

Scott v. Chipotle Mexican Grill, Inc.
94 F. Supp. 3d 585 · 2015-03-27
Motions to compel (plaintiff) Granted in part

“For the reasons stated below, the plaintiffs' motion to compel is granted in part and denied in part.”

Caseload & timing

From public federal docket records for this judge.

The reviewed 2025 assignments are led by Social Security disability appeals, often handled with the parties' consent, and also include insurance, employment, civil-rights, personal-injury, contract, and patent matters. This is a current sample rather than a tenure-wide caseload.

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