Maria del R. Antongiorgi-Jordan
How Judge Antongiorgi-Jordan decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
On a Rule 19 indispensable-party argument, requires the movant to show the absent party actually claims an interest in the litigation -- an unasserted, hypothetical interest is not enough to force dismissal.
“Here, simply put, the United States has not claimed an interest.”
In medical-malpractice and corporate-negligence claims, treats admissible expert testimony on causation as essential; a plaintiff's own account or a treating physician's notes, without more, will not defeat summary judgment on a non-obvious medical question.
“he fails to establish medical malpractice causation, as his experts did not provide sufficient admissible testimony to demonstrate that Defendants' negligence was the most probable cause of his grandmother's death.”
Will not re-litigate an argument the same case has already rejected for other co-defendants absent a materially different record, a change in law, newly discovered evidence, or manifest injustice -- repeating a predecessor's already-denied argument gets a short opinion, not a fresh analysis.
“The law of the case doctrine counsels against departing from the previous three similar findings on this issue... Defendant raises none of the above-mentioned circumstances in moving the Court deem count four duplicitous.”
In multi-defendant medical-malpractice cases, treats a nurse's standard of care as legally distinct from a physician's under Puerto Rico law; an expert report that thoroughly covers physicians but never discusses what a nurse or nurse practitioner owed the patient cannot support testimony against the nursing defendants, even if the same report would be admissible against the doctors.
“While all three expert opinions speak to the standard of care faced by physicians and/or medical institutions, nurses are subject to a distinct standard of care under Puerto Rico law in light of their distinct roles and responsibilities.”
Procedural preferences
Will grant summary judgment sua sponte -- even without a live pending motion -- once discovery has closed, the case is trial-ready, and both sides have already had a full opportunity to argue the dispositive issues in earlier briefing.
“Because both parties have had ample opportunity to argue, and have in fact argued, the issues decided below, any prejudice from a lack of further notice has been obviated.”
Treats an unopposed summary-judgment motion as still requiring an independent, in-depth review of the record before granting it -- unopposed is not the same as automatic.
“Taking those facts to be true, and after an in-depth review of the motion for summary judgment, the Court concludes that Plaintiff is entitled to Summary Judgment on its claims.”
On damages following a default judgment, holds a live evidentiary hearing (sworn testimony plus exhibits) and sets the award based on that record rather than the amount demanded in the complaint.
“once the entry of a default establishes the fact of damage, the trial judge... has considerable latitude in determining the amount of damages.”
On a Daubert/motion-in-limine challenge aimed at excluding an expert wholesale from a multi-defendant case, will parse the ruling defendant-by-defendant rather than issuing one blanket in-or-out result -- an expert can be barred as to one defendant's conduct while still admissible as to another's on the very same report.
“Dr. Ortiz may not, however, testify as to the nursing staff at Menonita Guayama. As such, Moving Defendants' Motion in Limine is GRANTED in part and DENIED in part.”
On a de novo bail/detention review, will credit a defendant's rebuttal of the statutory dangerousness presumption yet still order continued detention where the government's own proffer -- specific, corroborated evidence of violence or weapons, not just the presumption -- independently proves dangerousness by clear and convincing evidence.
“the Court agrees with Magistrate Judge López-Soler that the evidence proffered by Defendant was sufficient to rebut the presumption that detention is warranted. Nevertheless, after weighing the factors set forth in 18 U.S.C. § 3142(g), the Court concludes that the evidence proffered by the Government establishes by clear and convincing evidence that no condition or combination of conditions could reasonably assure the safety of the community.”
Cautions
A pro se litigant who keeps re-filing the same claims risks being formally labeled a vexatious litigant and ordered to show cause why future filings on the same subject should not require prior leave of court.
“Plaintiff is ORDERED TO SHOW CAUSE, no later than July 28, 2023, as to why the Court should not enjoin him from commencing any action of whatever type or description in the United States District Court for the District of Puerto Rico, in connection with his 2002 conviction for corruption without prior leave of the Court.”
A municipal/institutional-liability (Monell-style) claim pleaded only with formulaic recitations of an official policy or custom, without specific facts showing a widespread practice, will be dismissed even on a fifth amended complaint.
“Emblematic of the Complaint's insufficiently pled allegations are factually threadbare recitals... precisely the type of 'formulaic recitation of the elements of a cause of action' that are insufficient to state a claim.”
At summary judgment, conclusory allegations, unsupported speculation, or self-serving assertions unaccompanied by record citations get no evidentiary weight -- a party resisting judgment needs specific, citable facts.
“The Court 'must take the evidence in the light most flattering to the party opposing summary judgment'... but may 'afford no evidentiary weight to conclusory allegations, empty rhetoric, unsupported speculation, or evidence which, in the aggregate, is less than significantly probative.'”
Signed rulings
A grounded sample of orders signed by this judge, with the verbatim dispositive language.
“Defendants' Motion to Dismiss pursuant Fed. R. Civ. P. 12(b)(6) is GRANTED. Plaintiff's Complaint is DISMISSED with PREJUDICE.”
“Consequently, the Court ADJUDGES and DECREES that Defendant acted negligently, and such negligent actions were the cause of Plaintiffs' damages... once the entry of a default establishes the fact of damage, the trial judge... has considerable latitude in determining the amount of damages.”
“For the reasons set forth above, the Court DENIES Defendants' Motion to Dismiss the Indictment based on their jurisdictional challenges under the MDLEA and their due process claims.”
“There are thus no genuine issues of material fact warranting this case be sent to trial, and Defendant's Motion for Summary Judgment is GRANTED. Judgment shall be entered accordingly.”
“Given that the contract mandates any liability for damages or otherwise shall be limited to proceeds of insurance policies, and the fact the United States has not claimed an interest in the matter, the United States is not a necessary party... Their motion is thus DENIED WITHOUT PREJUDICE.”
“Plaintiffs' Complaint lacks specific factual allegations of a widespread practice amounting to de facto policy or deliberate indifference by policymakers... Plaintiffs' Fifth Amended Complaint is DISMISSED without prejudice and all other pending motions are rendered moot.”
“This alone merits dismissal... he fails to establish medical malpractice causation, as his experts did not provide sufficient admissible testimony... Accordingly, this medical malpractice action is DISMISSED with prejudice in its entirety. Defendants' Motion for Summary Judgment is GRANTED.”
“For the reasons stated above, the Court will not disturb the Middle District of Florida's ruling and finds that it has jurisdiction to issue the writ of execution. Defendant's Motion is thus DENIED.”
“The law of the case doctrine counsels against departing from the previous three similar findings on this issue... Accordingly, for the reasons stated above, Defendant's Motion to Dismiss is DENIED.”
“For the reasons stated hereafter, the Court GRANTS Summary Judgment in Defendant's favor sua sponte, thereby summarily dismissing this action... Summary Judgment is thus GRANTED in Defendant's favor sua sponte. All remaining pending motions are DENIED as MOOT.”
“Accordingly, summary judgment is not warranted and the instant motion is DENIED.”
“Taking those facts to be true, and after an in-depth review of the motion for summary judgment, the Court concludes that Plaintiff is entitled to Summary Judgment on its claims... For the reasons set forth above, the Court finds that summary judgment is warranted.”
Caseload & timing
From public federal docket records for this judge.
Her docket mixes a substantial inherited caseload -- cases assigned to her that were filed years to decades before her December 2022 appointment (examples span 1996, 2005, 2008, 2016-2021), evidently reassigned matters where a predecessor judge did most of the work -- with a fast-growing docket of her own newly filed cases since December 2022. The new caseload spans personal-injury and product-liability suits, medical malpractice, employment and ADA claims, prisoner civil-rights and habeas petitions, civil forfeiture, contract and foreclosure actions, and criminal narcotics and money-laundering prosecutions.
Put Judge Antongiorgi-Jordan's record to work
Ezel drafts and answers grounded in this exact profile: how Judge Antongiorgi-Jordan actually rules, not a generic AI guess.
Opens in Ezel Pro. Every answer is grounded in Judge Antongiorgi-Jordan's own signed orders and cites them.