Rachel Sarah Bloomekatz
How Judge Bloomekatz decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
Distinguishes controlling precedent by its precise doctrinal domain rather than its surface facts -- owner-liability cases about leaving keys in a car do not govern statutory product-liability claims against a manufacturer, because the two turn on different foreseeability questions. A litigant who frames the analogy at the right level of generality can survive a 12(b)(6) dismissal grounded on adverse precedent.
“We hold that those cases do not control product liability claims against car manufacturers, and that the design defect claims therefore survive.”
Strict, text-anchored reading of appellate jurisdiction under FAA s 16(a): she reviews only the ruling that actually 'denied' the motion to compel and refuses to sweep in related pro-arbitration rulings (contract formation) via pendent jurisdiction, citing the FAA's one-way ratchet favoring arbitration. Judicial-economy arguments do not move her on jurisdiction.
“Section 16(a) allows us to review an interlocutory ruling on contract formation only when that ruling supplied the basis for the district court's denying a motion to compel arbitration.”
On the FAA merits she enforces the 'default' rule with bite: a party that pursues complete victory on the merits in court before invoking arbitration forfeits it. The 'heads I win, tails you lose' posture is fatal.
“By seeking complete victory on the merits in the district court without invoking its arbitration rights even in the alternative, Laundry Service manifested its intent to litigate rather than arbitrate this dispute.”
Reads civil-rights and employment pleading standards charitably at the motion-to-dismiss/leave-to-amend stage, repeatedly correcting district courts that import a summary-judgment-era prima facie burden into Rule 12 review (FMLA retaliation and Title IX discrimination claims need only be plausibly alleged, not proven).
“Ahmed need only plausibly allege that she was retaliated against because of her FMLA leave.”
On summary judgment in favor of police officers, insists on a genuine (not nominal) concession of the plaintiff's version of the facts before exercising interlocutory qualified-immunity jurisdiction; a defendant who argues around disputed facts while claiming to concede them loses the appeal for lack of jurisdiction rather than winning on the merits.
“a concession in name only is no concession at all.”
Signed rulings
A grounded sample of orders signed by this judge, with the verbatim dispositive language.
“We affirm the district court's dismissal of Strench's and Moshi's manufacturing defect and nonconformance claims. We reverse the dismissal of their design defect and warning claims and remand for further proceedings consistent with this opinion.”
“We dismiss Laundry Service's appeal in part for lack of jurisdiction; otherwise we affirm the district court's judgment and deny Schnatter's request for sanctions.”
“We affirm the district court's denial of compassionate release.”
“We therefore reject the Mukhdomis' contention that the fines were grossly disproportional under the Eighth Amendment, and we affirm the district court's imposition of $125,000 in fines for each defendant.”
“We accordingly reverse the district court's grant of summary judgment to the officers.”
“We affirm Blake's conviction and remand Blake's sentence to the district court for further actions consistent with this opinion as to the second and third challenged special conditions of supervised release.”
“We dismiss Oxlaj-Perez's petition for review as untimely.”
“We vacate the district court's dismissal, reverse the district court's decision that allowing Ahmed leave to file her Fourth Amended Complaint would be futile, and remand for further proceedings consistent with this opinion.”
“For the foregoing reasons, we affirm the district court's judgment as to Plaintiffs 3-46 but reverse and remand for further proceedings as to Plaintiffs 1 and 2.”
“Because Gray can proceed on a theory of vicarious liability based on the supervisor's alleged bias, we reverse.”
“We affirm in part and reverse in part, remanding to the district court to consider several statutory claims it erroneously dismissed.”
“Given these errors, we reverse the grant of summary judgment, vacate the trial verdict, and remand the case to the district court.”
Put Judge Bloomekatz's record to work
Ezel drafts and answers grounded in this exact profile: how Judge Bloomekatz actually rules, not a generic AI guess.
Opens in Ezel Pro. Every answer is grounded in Judge Bloomekatz's own signed orders and cites them.