Camela Catherine Theeler

United States District Court for the District of South Dakota district Appointed by Joe Biden (Democratic) 1 signed orders read

How Judge Theeler decides

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

What persuades

She construes pro se complaints liberally at the 28 U.S.C. 1915 screening stage and will let a Fourteenth Amendment procedural-due-process claim proceed where the plaintiff plausibly alleges a protected liberty interest plus a lack of notice and a meaningful opportunity to be heard. She treats a parent's role in the care and custody of her children, and the continued possession of a driver's or professional (CNA) license, as protected interests under Bell v. Burson and Barry v. Barchi.

“Buffalo has provided enough facts to state a plausible procedural due process violation, and her Fourteenth Amendment due process claim against Rodriguez in her individual capacity for money damages and official capacity for injunctive relief survives 1915 screening.”

Procedural preferences

Her due-process analysis follows the standard two-step frame -- first whether a protected liberty or property interest is at stake, then what process is due under Mathews v. Eldridge -- and she anchors the 'what process is due' inquiry in the fundamental requirement of an opportunity to be heard at a meaningful time and in a meaningful manner.

“The fundamental requirement of due process is the opportunity to be heard 'at a meaningful time and in a meaningful manner.'”

On summary judgment against a pro se plaintiff, she enforces the local rule that a movant's statement of undisputed material facts is deemed admitted unless the opposing party responds paragraph-by-paragraph with record citations -- a pro se plaintiff's verified complaint and scattered filings are not enough to controvert a properly supported statement of facts.

“While Mr. Roberts filed pleadings opposing Dr. Boyd's motion for summary judgment ... Mr. Roberts did not respond to Dr. Boyd's statement of undisputed material facts with separately numbered paragraphs and appropriate citations to the record. ... Therefore, the Court deems admitted the facts set forth in Dr. Boyd's statement of undisputed material facts.”

She treats Rule 59(e)/60(b) reconsideration as a narrow, limited-function tool: it cannot be used to raise arguments or evidence that could have been -- but were not -- raised before judgment, even where the movant frames the new material as an overlooked objection to a magistrate's report and recommendation.

“Rule 59(e) motions cannot be used to introduce new evidence, tender new legal theories, or raise arguments which could have been offered or raised prior to the entry of judgment.”

Cautions

She enforces AEDPA's one-year time bar strictly and requires genuine new evidence -- not just renewed argument that a witness lied -- to invoke the actual-innocence gateway; a habeas petitioner's own insistence that the victim perjured herself, without more, does not come close to showing that no reasonable juror would have convicted.

“Delehoy provides no new evidence to rebut the factual determinations made by the jury at trial in arriving at his guilty verdict. ... his habeas petition under § 2254 is dismissed with prejudice as to all respondents.”

She reads Bivens narrowly: an Eighth Amendment medical-care claim against BOP medical staff falls outside the three contexts the Supreme Court has recognized (Bivens/Fourth Amendment, Davis/Fifth Amendment, Carlson/Eighth Amendment failure-to-treat resulting in death), so a delay-in-treatment theory without evidence the delay caused harm will not survive summary judgment even assuming Bivens applies.

“Mr. Roberts's Bivens claim against Dr. Boyd falls outside the three contexts in which the Supreme Court has recognized Bivens as a remedy.”

Signed rulings

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

Buffalo v. South Dakota Department of Social Services
5:25-cv-05040-CCT · 2026-05-12

Pro se IFP suit by Keshia Latonne Buffalo against state, tribal, and private defendants arising from a child-protective-services matter, a family safety plan, and the suspension of her CNA and driver's licenses for past-due child support. 45-page order: IFP granted, followed by a detailed 28 U.S.C. 1915 screening. Liberally construing the complaint, Theeler held several Fourteenth Amendment procedural-due-process claims plausible and let them proceed -- against CPS assessor Rafina Rodriguez (individual + official capacity) and Child Support Enforcement caseworkers Jane Bales and Erin Burke -- on a lack-of-notice theory (no meaningful opportunity to be heard before the safety plan or before the license suspensions), citing Mathews v. Eldridge, Bell v. Burson, and Barry v. Barchi. Claims against purely private non-state actors analyzed under the state-action requirement. The retrieved text truncated at ~page 27 of 45, so the complete list of dismissed claims/defendants was not read; only surviving-claim holdings are quoted here.

Caseload & timing

From public federal docket records for this judge.

The reviewed caseload mixes largely pending 2025–2026 filings with an inherited group of older cases that have mostly terminated. Prisoner civil-rights and habeas matters are overrepresented because those inherited cases produced clear, dated dispositive rulings, so the mix is descriptive rather than court-wide.

Put Judge Theeler's record to work

Ezel drafts and answers grounded in this exact profile: how Judge Theeler actually rules, not a generic AI guess.

Opens in Ezel Pro. Every answer is grounded in Judge Theeler's own signed orders and cites them.