Joan Louise Larsen
How Judge Larsen decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
Decides Sec 1983 claims arising from vacated convictions strictly on the merits, in both directions: a vacated conviction does NOT by itself make the officer liable (Chancellor -- affirmed summary judgment for the officer where the warrant affidavit and probable cause held up), but where the record shows the detective deliberately buried exculpatory evidence she will affirm a large plaintiff's verdict (Ansari -- $10M, Brady).
“A jury found for Ansari and awarded him $10 million in damages. Jimenez now appeals. We AFFIRM.”
Reads the Heck v. Humphrey bar narrowly: once the underlying conviction has actually been vacated, Heck poses no barrier to a Sec 1983 damages suit attacking the investigation.
“The Heck bar does not apply here.”
In ERISA fiduciary disputes she enforces the statute's federal-preemption scheme strictly against the fiduciary itself, holding an insurer bound by its plan's governing-law choice even where a stricter state insurance mandate exists elsewhere (BlueCross), and applies neutral common-law and statutory-preemption principles evenhandedly even in an extreme fact pattern (denying a convicted murderer his victim's life-insurance proceeds in Standard Ins. v. Guy).
“The district court disagreed, concluding either that ERISA does not preempt Tennessee's slayer statute or that the federal common law prevents Guy from benefitting from his murders. Guy now appeals. We AFFIRM.”
In immigration motions to reopen, holds petitioners to the formal Matter of Lozada requirements for ineffective-assistance claims (a bar complaint or an adequate explanation for not filing one) with little tolerance for conclusory excuses -- and will keep enforcing that same rule against the same petitioner years later on a second motion.
“Because we think Lozada requires more than a simple statement that the alien is ‘not interested in filing a formal complaint,’ we DENY the petition for review.”
Procedural preferences
On a criminal appeal she reviews jury-instruction, evidentiary, and sufficiency challenges and will affirm across the board where the record supports the verdict -- a high bar for a defendant-appellant to clear.
“He appealed, challenging the jury instructions, the admission of certain evidence, and the sufficiency of the evidence to support the conspiracy charges. We AFFIRM.”
Applies waiver/invited-error doctrine readily against criminal appellants who confirm on the record at sentencing that the court has addressed all their arguments, even reframing a forfeiture argument as waiver or invited error sua sponte rather than reaching the merits.
“Carter is not entitled to relief because he either waived his right to bring this challenge or invited the alleged error, and no manifest injustice will result from declining to consider his challenge.”
Will vacate and remand a supervised-release ruling (rather than simply affirm) when the district court's stated rationale does not track the correct legal standard, even in a case the government did not oppose -- her one outright appellant win in this set.
“For the reasons stated, we VACATE and REMAND for reconsideration of Hale's motion.”
Signed rulings
A grounded sample of orders signed by this judge, with the verbatim dispositive language.
“The district court granted summary judgment to Geelhood. Chancellor now appeals. We AFFIRM.”
“He appealed, challenging the jury instructions, the admission of certain evidence, and the sufficiency of the evidence to support the conspiracy charges. We AFFIRM.”
“A jury found for Ansari and awarded him $10 million in damages. Jimenez now appeals. We AFFIRM.”
“On appeal, Parrish challenges the reasonableness of his sentence. We AFFIRM.”
“Bailey now argues that her sentence was procedurally and substantively unreasonable. We disagree and AFFIRM the district court's sentence.”
“We lack authority to resolve the matter, however, because the Administrator's order was not a ‘final decision’ within the meaning of 21 U.S.C. Sec 877. Accordingly, we DISMISS the petition for review for lack of jurisdiction.”
“The district court granted summary judgment to FAMC on its breach of contract claims against UNB. We now AFFIRM that judgment.”
“Enchant appealed and, for the reasons set forth below, we AFFIRM.”
“Because Rehaif does not support Hobbs's challenges, we AFFIRM.”
“The district court rejected both claims, and we AFFIRM.”
“We agree and AFFIRM the judgment of the district court.”
Put Judge Larsen's record to work
Ezel drafts and answers grounded in this exact profile: how Judge Larsen actually rules, not a generic AI guess.
Opens in Ezel Pro. Every answer is grounded in Judge Larsen's own signed orders and cites them.