Michael Stefan Nachmanoff
How Judge Nachmanoff rules, drawn from 24 signed orders. Every observation links to the order it came from.
About Judge Nachmanoff
Michael Stefan Nachmanoff is a judge of the United States District Court for the Eastern District of Virginia. Appointed by President Joseph R. Biden, Judge Nachmanoff received a commission on November 2, 2021.
Judge Nachmanoff's practices and standing orders
The court's website lists no individual practices or standing orders of Judge Nachmanoff's own (checked October 9, 2026), so the court's local rules and general orders are the place to look (court page ↗).
Standing orders for every case in this court
Orders the court applies to all of its cases, whichever judge has them, as published on the court's website (checked October 9, 2026).
How Judge Nachmanoff decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
In Longworth v. Mansukhani, Nachmanoff authored a Fourth Circuit opinion while sitting by designation. The panel dismissed a Bivens appeal after holding that the FTCA judgment bar precluded a claim arising from the same conduct as the adjudicated FTCA suit.
“Put simply, the plain language of 28 U.S.C. § 2676 could not be clearer: this action cannot proceed.”
In Hernandez Lovo v. Crawford, he held that § 1226(a) governed the detention of a petitioner who had lived in the United States for roughly twenty-nine years.
“Because Petitioner has been present in the United States for roughly twenty-nine years, and because § 1226(a) sets forth ‘the default rule’ for detaining and removing noncitizens ‘already present in the United States,’ Jennings v. Rodriguez, 583 U.S. 281, 303 (2018), his detention is governed by § 1226(a).”
In Sramek, Nachmanoff upheld termination of disability benefits after finding the ERISA administrator’s decision reflected a reasoned process and substantial record evidence.
“United of Omaha’s decision was both the product of a deliberate, principled reasoning process, and supported by substantial evidence in the record.”
In Hundur, he distinguished a parent’s efforts to reunite with a child after removal from lasting consent to the child’s permanent residence in the United States.
“But his efforts to reunite with AH after AH’s removal do not show consistent agreement over time to permanently turning control over to Barut or allowing AH to stay in the U.S. in his absence.”
Procedural preferences
In Howell v. Walrath, Nachmanoff denied the prisoner’s discovery motion while granting dismissal of an inadequately pleaded civil-rights complaint. He explained that discovery could not supply a claim the complaint failed to state.
“Discovery should follow the filing of a well-pleaded complaint. It is not a device to enable a plaintiff to make a case when his complaint has failed to state a claim.”
As a magistrate he flagged threshold venue / personal-jurisdiction defects early and recommended dismissal where the suit had no connection to Virginia, rather than reaching the parties' default-related motions.
“Plaintiff's Complaint does not allege that Defendant has any ties to Virginia or that the alleged conduct occurred within Virginia. The alleged violations took place in Chicago, Illinois, where UICCOM is located.”
In Pagan, Nachmanoff dismissed a successive § 2254 petition without prejudice because the petitioner had not obtained Fourth Circuit authorization.
“Because Petitioner has not provided such an order from the United States Court of Appeals for the Fourth Circuit, this Court therefore lacks jurisdiction to consider this successive petition, which must be dismissed.”
In Smith, Nachmanoff required facts connecting a specific housing defendant to knowledge of protected activity before allowing an FHA retaliation claim against it.
“The Court finds this allegation conclusory and insufficient to support a claim that Defendant Eisenhower had knowledge of Plaintiff’s protected activity.”
Cautions
On the procedural posture of multi-suit litigation: a plaintiff who pursues both an FTCA claim and a Bivens claim on the same facts risks losing the Bivens claim entirely once any FTCA judgment is entered.
“a plaintiff who pursues both remedies ‘runs the risk that [the] constitutional claim will be subject to the FTCA's 'judgment bar' provision.’”
In Hernandez Lovo v. Crawford, Nachmanoff granted an immigration-detention habeas petition after concluding that the petitioner’s long residence placed his detention under 8 U.S.C. § 1226(a). He ordered release pending an individualized bond hearing.
“For all the reasons stated above, the Petition (ECF 1) is GRANTED.”
In a school-related civil-rights suit, further amendment was denied as futile after the amended pleading failed to establish the asserted duty and other required elements.
“This Court finds that any amendment would be futile and dismisses the Amended Complaint with prejudice.”
Signed rulings
A grounded sample of orders signed by this judge, with the verbatim dispositive language.
“plaintiff's motion for discovery will be denied, and defendants' motions to dismiss will be granted.”
“Accordingly, the Court will deny plaintiff's motion for discovery and proceed to assess defendants' Motions to Dismiss, which question the sufficiency of the allegations in the complaint.”
MAGISTRATE-ERA Report & Recommendation (a recommendation to the district judge, NOT a final ruling, and from his prior magistrate role, so EXCLUDED from district motion stats; recorded for the pattern layer + as an order read). Pro se Title IX / defamation suit by a former University of Illinois Chicago medical student against a UIC dean. On a plaintiff's motion for default judgment and a defendant's motion to set aside default, Nachmanoff (then a U.S. Magistrate Judge) recommended the complaint be DISMISSED for lack of personal jurisdiction and improper venue, all events occurred in Chicago, Illinois, with no Virginia ties. Adoption by the district judge not verified. (In the public archive, this E.D. Va. recommendation was indexed under an unrelated district's records.) Grounding quote: 'the undersigned recommends that Plaintiff's Complaint against Defendant be dismissed for lack of jurisdiction.'
APPELLATE panel opinion AUTHORED by Nachmanoff sitting by designation on the Fourth Circuit (joined by Judges Agee and Richardson): not a district-court motion ruling, so EXCLUDED from district motion stats; recorded for the pattern layer. A federal inmate brought parallel Bivens and FTCA suits over alleged FBOP sexual abuse; after a merits judgment dismissed the FTCA claim, the panel held the FTCA judgment bar (28 U.S.C. 2676) precludes the still-pending Bivens appeal arising from the same conduct, and dismissed the appeal. Shows his textualist reading of the judgment bar and his treatment of a jurisdictional FTCA dismissal as a 'judgment on the merits' under Brownback. Grounding quote: 'Put simply, the plain language of 28 U.S.C. § 2676 could not be clearer: this action cannot proceed.'
“ORDERED that the Petition be and is filed; and it is further ORDERED that on or before 5:00 pm on Tuesday, September 9, 2025, Respondents show cause why the Petition should not be granted.”
“ORDERED that Mr. Lopez-Sanabria be released from custody no later than 4:00 pm on Friday, October 3, 2025, with all his personal property, once he has posted the $1,500 bond set by the Immigration Judge; and it is further ORDERED that Respondents...along with their officers, agents, servants, employees, attorneys, successors, and assigns, and all persons acting in concert with them be and are ENJOINED from rearresting Mr. Lopez-Sanabria unless he has committed a new violation of any federal, state, or local law, or has failed to attend any properly noticed immigration or court hearing.”
“ORDERED that the Petition (ECF 1) is GRANTED, and it is hereby ORDERED that to the extent that Petitioners seeks release from detention, Petitioners file a motion requesting a bond hearing or custody redetermination as soon as practicable; and that Federal Respondents provide Petitioners with a standard bond hearing before an IJ pursuant to 8 U.S.C. § 1226(a) within 7 days of the date of that motion; and it is further ORDERED that Federal Respondents are ENJOINED from denying bond to Petitioners on the basis that they are detained pursuant to 8 U.S.C. § 1225(b)(2).”
“ORDERED that the Petition (ECF 1) is GRANTED, and it is hereby ORDERED that to the extent that Petitioner seeks release from detention, Petitioner files a motion requesting a bond hearing or custody redetermination as soon as practicable; and that Federal Respondents provide Petitioner with a standard bond hearing before an IJ pursuant to 8 U.S.C. § 1226(a) within 7 days of the date of that motion; and it is further ORDERED that Federal Respondents are ENJOINED from denying bond to Petitioner on the basis that he is detained pursuant to 8 U.S.C. § 1225(b)(2).”
“ORDERED that the Petition (ECF 1) is GRANTED, and it is hereby ORDERED that to the extent that Petitioners seek release from detention, Petitioners file a motion requesting a bond hearing or custody redetermination as soon as practicable; and that Federal Respondents provide Petitioners with a standard bond hearing before an IJ pursuant to 8 U.S.C. § 1226(a) within 7 days of the date of that motion; and it is further ORDERED that Federal Respondents are ENJOINED from denying bond to Petitioners on the basis that they are detained pursuant to 8 U.S.C. § 1225(b)(2).”
“ORDERED that the Petition (ECF 1) is GRANTED, and it is hereby ORDERED that to the extent that Petitioner seeks release from detention, Petitioner file a motion requesting a bond hearing or custody redetermination as soon as practicable; and that Federal Respondents provide Petitioner with a standard bond hearing before an IJ pursuant to 8 U.S.C. § 1226(a) within 7 days of the date of that motion; and it is further ORDERED that Federal Respondents are ENJOINED from denying bond to Petitioner on the basis that he is detained pursuant to 8 U.S.C. § 1225(b)(2).”
“ORDERED that Defendants' Motion for Summary Judgment re 22, is GRANTED IN PART and DENIED IN PART. The Motion is GRANTED as to Count III of Plaintiff's Amended Complaint re 18, and claims in Count II of the Amended Complaint related to Plaintiff's suspension without pay on June 18, 2025. The Motion is otherwise DENIED as to Counts I, II, and IV. ORDERED that Plaintiff's Motion for Partial Summary Judgment re 32, is DENIED. ORDERED that Count III of Plaintiff's Amended Complaint is DISMISSED.”
“ORDERED that Plaintiff's Motion for Partial Summary Judgment re 32, is DENIED.”
“MEMORANDUM OPINION AND ORDER Denying Plaintiff's Rule 56(d) Motion (ECF 74); Granting Defendant's Motion to Dismiss (ECF 69); and Dismissing Plaintiff's Second Amended Complaint (ECF 43).”
“ORDERED that the United States's Partial Motion to Dismiss (Dkt. No. 20) is GRANTED; it is further ORDERED that the claims asserted against Defendants Cain and Parker are DISMISSED WITH PREJUDICE; and it is further ORDERED that all claims asserted by Plaintiff J.L. are DISMISSED WITH PREJUDICE.”
Caseload & timing
From public federal docket records for this judge.
Median motion-to-ruling time: 27 days (N = 11).
The sampled Alexandria civil docket includes immigration-agency review, naturalization mandamus, insurance declaratory judgment, contract, prisoner civil rights, and § 2255 matters. Mid-2026 assignments are heavily concentrated in alien-detainee petitions under 28 U.S.C. § 2241. This is a qualitative description of the reviewed cases, not a counted population distribution.
Pending matters in the official report
Reported by the Administrative Office of the U.S. Courts under the Civil Justice Reform Act, as of March 31, 2026.
| Motions pending more than six months | 0 |
| Bench trials submitted more than six months | 0 |
| Bankruptcy appeals pending more than six months | 0 |
| Social Security appeals pending more than six months | 0 |
| Civil cases pending more than three years | 1 |
| Report | Motions over six months | Cases over three years |
|---|---|---|
| Mar 2026 | 0 | 1 |
| Sep 2025 | 4 | 1 |
| Mar 2025 | 0 | 0 |
| Sep 2024 | 0 | 0 |
| Mar 2024 | 0 | 0 |
| Sep 2023 | 3 | 2 |
| Mar 2023 | 0 | 0 |
| Sep 2022 | 0 | 0 |
| Mar 2022 | 0 | 0 |
| Sep 2021 | 0 | 0 |
| Mar 2021 | 0 | 0 |
| Sep 2020 | 0 | 0 |
A snapshot on that date: matters listed may since have been decided or reassigned. A motion referred to a magistrate judge is counted for both judges. Motions in multidistrict litigation, section 2255 cases and Social Security appeals are not counted, and a very large three-year count is generally a multidistrict docket. Source: Appendix A of the report (PDF); about the report.
How long civil cases take in this court
For the whole of United States District Court for the Eastern District of Virginia, not for Judge Nachmanoff: median time from filing to disposition of the civil cases the court closed in the 12 months ending September 30, 2025, as reported by the Administrative Office of the U.S. Courts.
| Cases | Median time | |
|---|---|---|
| All civil cases closed | 3,011 | 5.6 months |
| Closed with no court action | 1,204 | 5 months |
| Closed before pretrial | 1,299 | 4.9 months |
| Closed during or after pretrial | 493 | 8.9 months |
| Closed during trial | 15 | 19.3 months |
| 12 months ending | Cases closed | Median time |
|---|---|---|
| Sep 2025 | 3,011 | 5.6 months |
| Sep 2024 | 2,613 | 5.3 months |
| Sep 2023 | 2,194 | 6.5 months |
| Sep 2022 | 2,134 | 6.8 months |
| Sep 2021 | 2,152 | 6.5 months |
| Sep 2020 | 1,860 | 6 months |
| Sep 2019 | 2,267 | 5.9 months |
The table leaves out prisoner petitions, land condemnations, deportation reviews, recovery of overpayments and enforcement of judgments, and reports no median for fewer than 10 cases. A district that closed a large multidistrict litigation in the period shows very large counts and long medians for that year. Source: Table C-5, U.S. District Courts (spreadsheet).
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