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Paul Gerhart Hatfield

United States District Court for the District of Montana district Retired 2000 · served 1979–2000 Appointed by Jimmy Carter (Democratic) 22 signed orders read

Judge Hatfield no longer hears cases. This profile is preserved as a historical record of how they ruled.

How Judge Hatfield decides

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

What persuades

Hatfield treated a genuine factual dispute over constructive discharge as a question for the jury.

“the determination regarding whether the defendant’s conduct constructively discharged the plaintiff in the present action is a question of fact for a jury to decide.”

He required comprehensive environmental review before federal agencies could commit national-forest lands to oil and gas leasing.

“The federal agencies violated the procedural requirements of NEPA by failing to prepare an EIS on the effects of oil and gas activity on the Flathead and Gallatin National Forests.”

Hatfield treated a fee imposed directly on federal property before government work could proceed as an unconstitutional burden.

“Consequently, the fees place a direct burden upon the United States in the execution of its governmental functions in violation of the supremacy clause.”

Procedural preferences

At the pleading stage, Hatfield accepted a plaintiff's well-pleaded discovery allegation and left a limitations fact question for later resolution.

“Accordingly, it cannot be said, as Dow Company suggests, that the allegations of Sternhagen’s complaint are legally insufficient to establish a claim.”

He regarded supplementation of an administrative record as exceptional but permitted focused discovery when a recognized exception applied.

“Supplementation of an administrative record is the exception, not the rule.”

Hatfield strictly construed federal removal jurisdiction and remanded intertwined state and third-party contract claims.

“Both actions arise from the same set of operative facts with the principal claim and third-party claim being inextricably intertwined.”

Cautions

A tax-refund claimant's failure to sign and verify amended returns left no valid administrative claim to support suit.

“Since the unsigned and unverified returns filed by the plaintiff are no returns at all, the court deems the motion to dismiss advanced by the defendant to have merit.”

A franchisor's legitimate financial interest could privilege its refusal to approve a proposed franchisee.

“The defendants clearly had a financial interest in the subject dealership which, in this court’s opinion, gave rise to a privilege as to plaintiffs’ allegations of malicious interference with contract.”

Hatfield allowed a jurisdictional defense to be raised successively because subject-matter jurisdiction cannot be waived.

“There is no question that subject matter jurisdiction is not waivable.”

Signed rulings

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

Central Montana Electric Power Cooperative, Inc. v. Administrator of the Bonneville Power Administration
· 1987-02-13
Motions to transfer (plaintiffs) Granted

“IT IS HEREBY ORDERED that this action shall be transferred to the United States Court of Appeals for the Ninth Circuit. The Clerk of Court shall, forthwith, do all things necessary to effectuate said transfer.”

Wattelet v. Toyota Motor Corp.
· 1987-04-27
Summary judgment (defendants) Granted

“IT IS HEREBY ORDERED that defendants’ motion for partial summary judgment dismissing plaintiffs’ ‘air bag claim’ is GRANTED.”

Brotherhood of Locomotive Engineers v. Burlington Northern Railroad
· 1985-07-31
Summary judgment (defendant) Granted

“IT IS ORDERED that the defendant’s motion for summary judgment be, and the same hereby is, GRANTED.”

Maxwell v. Sisters of Charity of Providence
· 1986-10-24
Summary judgment (defendants) Granted

“IT IS HEREBY ORDERED that defendants are GRANTED summary judgment on Counts Three, Four and Five of plaintiff’s amended complaint.”

Blackfeet Indian Nation v. Hodel
· 1986-03-27
Summary judgment (state defendants) Granted

“IT IS HEREBY ORDERED AND ADJUDGED that the motion for summary judgment filed by the state defendants be, and the same hereby is, GRANTED.”

Motions to dismiss (federal defendants) Granted

“IT IS FURTHER ORDERED AND ADJUDGED that the federal defendants’ motion to dismiss be, and the same hereby is, GRANTED, and this action is DISMISSED in its entirety-”

Pfeiffer v. MacMillan Publishing Co.
· 1982-01-19
Motions to remand (plaintiffs) Denied

“Accordingly, it is HEREBY ORDERED that the motion to remand, filed by the plaintiff herein, be, and the same hereby is, DENIED.”

Statewide Rent-A-Car, Inc. v. Subaru of America
· 1988-12-15
Summary judgment (defendants) Granted

“Furthermore, for the reasons set forth herein, the court concludes that as to plaintiffs’ original complaint, defendants’ motion for summary judgment be, and the same hereby is, GRANTED.”

Rainbow Electric Co. v. United States
· 1982-03-03
Motions to dismiss (United States) Granted

“Accordingly, IT IS ORDERED that the motion to dismiss for failure to state a claim upon which relief may be granted, submitted by the defendant, is hereby GRANTED and the complaint is DISMISSED.”

Bd. of Trustees of Montana Teamsters Emp. v. Coyne
· 1986-01-30
Summary judgment (defendants) Granted

“IT IS HEREBY ORDERED that the defendants’ motion for summary judgment be, and the same hereby is, GRANTED.”

Wheeler v. Valley Implement Co.
· 1984-10-01
Summary judgment (defendant) Granted

“For the reasons set forth above, IT IS TTF.RF.TiY ORDERED AND ADJUDGED that defendant’s motion for summary judgment be, and the same hereby is, GRANTED, and this action is DISMISSED.”

Midstate Bank v. Murray
· 1984-06-29
Motions to remand (plaintiff) Granted

“(ii) That the principal action and remaining portions of the third-party action be, and the same hereby are, REMANDED to the District Court of the Tenth Judicial District of the State of Montana.”

Oedewaldt v. JC PENNEY CO., INC.
· 1988-05-18
Summary judgment (defendant) Granted in part

“(1) defendant’s motion for summary judgment is GRANTED as to plaintiff’s negligence claims; (2) defendant’s motion for summary judgment is DENIED as to the remainder of plaintiff’s complaint; and”

Caseload & timing

From public federal docket records for this judge.

The 22 reviewed decisions cover a broad litigation sample, but they do not establish the distribution of Hatfield's full caseload.

A historical record

Judge Hatfield 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.