James Stuart Holden
Judge Holden no longer hears cases. This profile is preserved as a historical record of how they ruled.
How Judge Holden decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
In federal-preemption disputes, he focused on whether Congress had assigned exclusive authority to the federal regulator; once exclusivity was established, the conflicting state order could not stand.
“The jurisdiction of the Federal Energy Regulatory Commission over the licensing of hydroelectric plants on navigable waters of the United States is exclusive of the jurisdiction assumed by the Public Service Board majority over the licensing of the Chace Mill project.”
At summary judgment, he required evidence that could support the asserted theory, not an invitation to assume that missing facts might exist.
“The court cannot assume that such facts exist, and the record is void of any evidence upon which a trier of fact could find that the decision was fraudulent or arbitrary.”
Procedural preferences
He resolved immunity at summary judgment by separating conduct protected after judicial intervention from earlier conduct that still required trial.
“The threshold question of defendants’ immunity from trial must be resolved against their motion for summary judgment.”
Where dismissal rested on a threshold capacity defect, he declined to decide unsettled state-law limitations questions unnecessarily.
“By dismissing this complaint for lack of capacity, the Court leaves the novel and unsettled questions of recent Vermont statutory changes attending the limitations of actions to the state courts.”
Cautions
Invoking the federal Arbitration Act did not itself create jurisdiction; a party still needed an independent federal jurisdictional basis.
“The Arbitration Act, standing alone, is not an independent grant of jurisdiction; there must be some independent basis for jurisdiction of the federal courts.”
A post-conviction conflict claim required proof of an actual conflict that adversely affected counsel, not the mere possibility of divided loyalties.
“In order to establish a violation of the Sixth Amendment, a defendant who raised no objection at trial must demonstrate that an actual conflict of interest adversely affected his lawyer’s performance”
Signed rulings
A grounded sample of orders signed by this judge, with the verbatim dispositive language.
“For the reasons stated above, the court hereby grants the defendants’ motion to dismiss for lack of jurisdiction.”
“Because the court lacks subject matter jurisdiction, it is unnecessary to reach the motion for summary judgment.”
“The intervenor’s motion for partial summary judgment will be denied. The defendants’ motion to dismiss is denied. The plaintiffs’ motion for summary judgment is granted.”
“The plaintiffs’ motion for summary judgment is granted;”
“The defendants’ motion to bring in third-party defendants is denied;”
“The defendant’s motion for summary judgment must be denied; the plaintiff’s motion for summary judgment is granted.”
“In sum, the defendants are not entitled to absolute immunity for their conduct during the afternoon of August 26, 1981. The claims against the defendants Via and Harrison to recover for injuries sustained after judicial intervention by the juvenile court on the evening of August 26, 1981, must be dismissed.”
“The recommendation that the complaint against the defendant Secretary of Health and Human Services be dismissed is adopted.”
“The recommendation that the motion of the remaining state defendants for summary judgment be granted is adopted.”
“That the motions of the defendants to dismiss the action for lack of personal jurisdiction are granted.”
“That the motion of the plaintiff for relief from judgment under Fed.R.Civ.P. 59 and 60(b) is denied.”
“The Clerk will enter an order dismissing the action for lack of jurisdiction.”
“The petitioners’ motion to eliminate Middlebury Developers as a party plaintiff is denied.”
“Plaintiffs’ request for a temporary restraining order and preliminary injunction under Fed.R. Civ.P. 65 is denied.”
“The court will therefore grant to the defendant Nórdica USA partial summary judgment, under authority of rule 56(d) of the Federal Rules of Civil Procedure.”
“For these reasons, and the reasons stated above granting partial summary judgment to the defendant, the court will deny the plaintiff’s cross-motion for summary judgment.”
“The defendants’ motion to compel is DENIED.”
“That the defendant’s motion to dismiss is granted.”
Caseload & timing
From public federal docket records for this judge.
The two available case records are a completed Social Security matter filed in 1978 and a miscellaneous matter filed in 1993 that remains administratively open. Their pre-electronic entry streams are empty, so this very small sample supports only case-level dates, not motion timing or a representative caseload mix.
A historical record
Judge Holden no longer hears cases. This profile stays available as a record of how they ruled. If you're preparing for a matter, start from the court's current bench.