Sarah Elizabeth Daggett Morrison
How Judge Morrison decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
Enforces statutes of limitations strictly and will break with sister-court precedent to do so (held N.D. Ohio's Doe 1 'wrongly decided', applying Ohio's 2-yr personal-injury SOL to Title IX).
“A close reading of binding case law leads this Court to conclude that Doe 1 was wrongly decided.”
Refiling a complaint after a voluntary dismissal does NOT toll the 90-day Title VII / EEOC right-to-sue clock.
“the filing of a prior complaint does not toll the ninety-day period and the court cannot extend the time for filing.”
Procedural preferences
Recharacterizes the proper procedural vehicle when needed -- treats a Rooker-Feldman challenge as a Rule 12(b)(1) facial attack and dismisses jurisdictional defects WITHOUT prejudice.
“the Court finds a Fed. R. Civ. P. 12(b)(1) analysis more appropriate given Defendants' reliance upon the Rooker-Feldman doctrine.”
Enforces motion-practice timing against defendants too -- a personal-jurisdiction defense not timely raised is WAIVED, even citing intervening circuit precedent, because the controlling Supreme Court law predated the suit.
“Walmart's Motion to Dismiss is DENIED.”
A plaintiff may not smuggle in new claims through a summary-judgment response; new theories require leave to amend under Rule 15(a)(2). She also strikes memoranda filed without leave under S.D. Ohio Civ. R. 7.2(a)(2).
“a plaintiff may not assert new claims in her response to summary judgment.”
Cautions
Will not grant summary judgment on a credibility/swearing contest -- competing affidavits go to the jury.
“Credibility determinations, the weighing of the evidence, and the drawing of legitimate inferences from the facts are jury functions, not those of a judge[.]”
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 = 7 |
Granted: 5Denied: 2 | counts only |
| Summary judgment N = 5 |
Granted: 4Denied: 1 | counts only |
| Motion for leave to file N = 1 |
Denied: 1 | counts only |
| Motions to stay N = 1 |
Moot / procedural: 1 | counts only |
| Motion to transfer venue N = 1 |
Moot / procedural: 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 Court hereby ADOPTS the R&R (ECF No. 37), DENIES OhioHealth's Second Motion to Dismiss (ECF No. 33)”
“and DENIES Plaintiff's Motion for Leave to File Surreply (ECF No. 36)”
“the Township's Motion for Summary Judgment is GRANTED as to all claims.”
“Ohio State's Motion for Summary Judgment (ECF no. 42) is GRANTED. The Clerk is DIRECTED to TERMINATE this case.”
“ArmorSource's Motion for Summary Judgment (ECF No. 169) is DENIED.”
“The Motion to Dismiss of Defendants Judge Jamison and Franklin County is GRANTED. (ECF No. 18.) The Section 1983 claims are DISMISSED WITHOUT PREJUDICE.”
“Irvin's Motion to Dismiss is GRANTED and these claims are DISMISSED without prejudice. (ECF No. 9.)”
“For the foregoing reasons, Defendants' Motion to Dismiss (ECF No. 21) is GRANTED.”
“Defendants' Motion to Stay (ECF No. 9) and the three Motions to Strike (ECF Nos. 10, 18, and 22) are DENIED as moot.”
“For the reasons set forth above, Walmart's Motion to Dismiss is DENIED.”
“Accordingly, Plaintiffs' Motion to Transfer Venue is DENIED as moot.”
“Plaintiffs have failed to allege antitrust standing. The Court finds that no amendment to the Complaint could cure this failure because the insufficiency lies not in the specific claims but in the nature of the alleged harm. Defendants' Motion to Dismiss is GRANTED.”
“Defendant's Motion for Summary Judgment (ECF No. 24) is GRANTED. Judgment is entered in favor of Defendant the Ohio Department of Public Safety and the Clerk is DIRECTED to terminate the case.”
“For the reasons set forth above, Defendant's Motion for Summary Judgment (ECF No. 32) is GRANTED. The Clerk is DIRECTED to TERMINATE this case from the docket”
“the Troopers' Partial Motion to Dismiss is GRANTED. Mr. Yoder's Fourteenth Amendment claim, Fourth Amendment false arrest claim, Section 1983 civil conspiracy claim, and official capacity claims are DISMISSED with prejudice. Mr. Yoder's remaining claims are unaffected by this ruling.”
Caseload & timing
From public federal docket records for this judge.
Currently-assigned, inherited dockets terminated 2019-2022 (excludes 4 enumerated cases terminated before her 2019-06-14 commission). Nature-of-suit mix below.