Tiffany M. Cartwright

U.S. District Court for the Western District of Washington (Tacoma) Appointed by Joe Biden (Democratic) 2 signed orders read

How Judge Cartwright decides

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

What persuades

On removal/jurisdiction, applies the narrow 9th-Cir. complete-preemption test and will remand where state-law property (replevin/conversion) claims are not equivalent to the Copyright Act's exclusive rights. OEG v. Korum, Dkt. 51 (2025-01-31).

“Copyright law does not preempt state laws with respect to 'activities violating legal or equitable rights that are not equivalent to any of the exclusive rights within the general scope of copyright[.]'”

Procedural preferences

In ERISA LTD cases applies de novo review where the plan lacks a discretionary-authority clause, and will resolve procedural defenses (exhaustion via futility) in the claimant's favor before reaching the administrative-record merits. Stickley v. Unum, Dkt. 23 (2025-04-10).

“District courts review a plan administrator's denial of benefits 'under a de novo standard unless the benefit plan gives the administrator or fiduciary discretionary authority to determine eligibility for benefits.'”

Routinely adopts magistrate-judge R&Rs on pro se IFP/screening matters (Christel, Fricke). Crary v. WA, Dkt. 20; Briggs v. Aetna, Dkt. 9.

“ORDER ADOPTING 16 REPORT AND RECOMMENDATION. Plaintiff's Application to Proceed IFP (Dkt. 9) is denied and the proposed complaint is dismissed for failure to state a claim.”

Motion outcomes

Counted from classified signed orders only. Percentages are shown only where the sample is large enough to be meaningful; smaller samples are reported as raw counts.

Motions to remand
N = 1
Granted: 1 counts only
Motion for judgment
N = 1
Granted: 1 counts only
Cross motion for judgment
N = 1
Denied: 1 counts only
Motion to seal
N = 1
Granted: 1 counts only

A "1 of 1" is one ruling, not a tendency. Treat small samples as illustrative, not predictive.

Signed rulings

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

OEG Inc v. Korum
3:24-cv-05694-TMC · 2025-01-31
Motions to remand (plaintiff) Granted

“ORDER granting Plaintiff's 20 Motion to Remand. Per LCR 3(i), case will be remanded on the 15th day following the date of this Order, on 2/18/2025. Signed by District Judge Tiffany M. Cartwright.”

Motion to seal (defendant) Granted

“ORDER granting Defendants' 24 Motion to Seal; granting Plaintiff's 20 Motion to Remand.”

Stickley v. Unum Life Insurance Company of America
3:24-cv-05364-TMC · 2025-04-10
Motion for judgment (defendant) Granted

“ORDER granting Unum's 14 Motion for Judgment; denying Stickley's 15 Motion to Supplement the Administrative Record and 17 Cross-Motion for Judgment. Signed by District Judge Tiffany M. Cartwright.”

Cross motion for judgment (plaintiff) Denied

“denying Stickley's 15 Motion to Supplement the Administrative Record and 17 Cross-Motion for Judgment.”

Crary v. State of Washington
3:24-cv-05666-TMC · 2024-11-08

Read for coverage, EXCLUDED from motion stats (no party motion). Cartwright ADOPTED Magistrate Judge David W. Christel's R&R (Dkt. 16) -- pro se IFP application denied and complaint dismissed for failure to state a claim. Illustrates her R&R-adoption screening workflow.

Briggs v. Aetna Pharmacy Management
3:24-cv-05681-TMC · 2024-12-31

Read for coverage, EXCLUDED from motion stats (no party motion). Cartwright ADOPTED Magistrate Judge Theresa L. Fricke's R&R (Dkt. 7) -- pro se action dismissed without prejudice for failure to state a claim. Pro se plaintiff appealed to the 9th Cir.; Cartwright continued his IFP status on appeal (Dkt. 14, 2025-02-07).