Susan A. McManus
How Judge McManus rules, drawn from 12 signed orders. Every observation links to the order it came from.
How Judge McManus decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
In recognition-of-judgment disputes she applies comity and Restatement principles and treats another court's final judgment as presumptively valid, placing a heavy burden on the party attacking it; foreign procedures need not mirror Vermont's own rules to be fair.
“our Rules do not set the ‘floor,’ such that procedural rules that do not mirror ours are lacking in essential fairness.”
She sharply distinguishes statutes of repose from statutes of limitation but enforces the Legislature's express statutory exceptions to repose, here the minority-tolling provision, reading the interlocking statutes together, so a medical-malpractice claim brought within the tolled period survives a repose defense.
“This plainly states that the times imposed by section 521, in the case of a minor, begin upon their eighteenth birthday.”
She reads Rule 75 review of executive-agency action narrowly, as limited to mandamus over ministerial duties, and will not review an agency's discretionary decisions such as inmate medical-care determinations.
“Review of such discretionary decisions is not permitted under Rule 75.”
Procedural preferences
A party opposing summary judgment must come forward with actual record evidence; bare reliance on the pleadings or speculation will not create a genuine dispute of material fact.
“A party opposing summary judgment may not simply rely on allegations in the pleadings to establish a genuine issue of material fact. Instead, it must come forward with deposition excerpts, affidavits, or other evidence to establish such a dispute.”
She applies a demanding standard before revisiting an interlocutory ruling and will not cede control of the court's docket to a litigant through open-ended, blanket accommodations.
“The Court will not simply cede control over its docket to any litigant in a blanket fashion, such as is sought by Defendant.”
To reopen a default judgment she requires a specific, non-conclusory factual showing of excusable neglect and a meritorious defense tethered to the facts of the case.
“Ms. Taggart’s purported ‘meritorious defenses’ are thin legal arguments that are asserted in entirely conclusory terms that are not clearly tethered to the facts of this case.”
Cautions
A fee applicant should substantiate both the requested hourly rates and the necessity of the work. She may reduce fees where the case is straightforward, trial work resulted from an avoidable evidentiary failure at summary judgment, or attorney-rate billing covers administrative tasks.
“Fee awards are to be reasonable, reasonable as to billing rates and reasonable as to the number of hours spent in advancing the successful claims.”
Even under Vermont's lenient 12(b)(6) standard she dismisses discrimination and public-accommodations claims where the complaint fails to plead the plaintiff's own protected-class membership, injury in fact, and standing.
“To demonstrate standing, a plaintiff must allege injury in fact, causation, and redressability.”
She denies leave to amend where the proposed pleading would not cure the underlying defects.
“Mr. Billewicz’s proposed amended complaint is certifiably futile.”
An intentional-infliction-of-emotional-distress claim needs a single sufficiently extreme act; she will not let an accumulation of ordinary workplace slights be consolidated into outrageous conduct.
“Absent at least one incident of behavior that transcends the ignoble and vast realm of unpleasant and often stressful conduct in the workplace, incidents that are in themselves insignificant should not be consolidated to arrive at the conclusion that the overall conduct was outrageous.”
Signed rulings
A grounded sample of orders signed by this judge, with the verbatim dispositive language.
“Wherefor, Plaintiff’s motion for summary judgment is GRANTED.”
“For the foregoing reasons, Defendants’ motion for summary judgment is granted.”
“Mr. Billewicz’s motion to amend is denied.”
“For the foregoing reasons, the State’s motion for partial summary judgment is granted.”
“Mr. Cijka’s motion for summary judgment is granted in part and denied in part.”
“Defendant’s motion to dismiss Counts II, III, and IV is granted.”
“Defendant’s Partial Motion to Dismiss is granted with regard to the claims for third-party retaliation and intentional infliction of emotional distress. It is denied regarding the promissory estoppel claim based on reduction of retirement account contribution and granted with regard to the remaining bases for the promissory estoppel claim.”
“Accordingly, Dr. Wulfman’s motion to dismiss is denied.”
“Porter moves for judgment on the pleadings pursuant to V.R.C.P. 12(c), based on the statute of repose. For the reasons discussed above, the motion is denied.”
“Plaintiffs’ Motion for Protective Order is granted in part and denied in part.”
“Plaintiffs’ Motion for Scheduling Order for Trial and for Order Dealing with Other Trial Related Matters is denied.”
“Defendant’s motion for reconsideration and for accommodations, filed January 16, 2026, is hereby DENIED.”
“Ms. Taggart’s motion to set aside judgment is denied; the stay of execution entered on February 26, 2026, is lifted.”
“Defendant’s oral motion for sanctions made in court on November 19, 2025, is hereby GRANTED IN PART, and DENIED IN PART.”
“the Court declines Plaintiffs’ request to stay enforcing this order until all the claims in this case have been finally resolved on the merits, including by exhaustion of all appeals.”
“Accordingly, therefore, this action must be, and hereby is, DISMISSED for lack of subject matter jurisdiction.”
“For the foregoing reasons, the State’s motion to dismiss is granted.”
“Plaintiff’s request for recovery of fees and costs in granted in part and denied in part.”
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