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Decision levers
AI-measured from their own opinions — each lever cites its cases
Willing to revisit precedentStrong stare decisis
In disability cases such as Waters v. Astrue and Hawker v. Barnhart, the court adheres closely to Fourth Circuit precedents like Wilkins v. Secretary without questioning them. Waters v. Astrue ↗ Hawker v. Barnhart ↗
PurposivismTextualism
In Taylor the court parses the text of the assimilated Maryland traffic statute, while in Kennedy it examines the wording and amendments of Title VII's religious exemption to determine its scope. United States v. Taylor ↗ Kennedy v. Villa St. Catherine's… ↗
Deference to government powerSkepticism of government power
In multiple Social Security cases the court remands agency decisions after identifying legal errors in the ALJ's or Appeals Council's analysis rather than deferring to the Commissioner's conclusions. Waters v. Astrue ↗ Hawker v. Barnhart ↗ Barton v. Astrue ↗
In Lopez v. XTEL Construction Group, LLC, plaintiffs moved to enforce an oral settlement agreement reached during February 2011 conference calls with the magistrate judge, under which defendants would pay $10,000 in installments to resolve the claims, with default judgment as a consequence for nonpayment. The court first addressed whether the magistrate judge should recuse under 28 U.S.C. § 455 due to participation in the settlement discussions, concluding that no disqualification was required because all knowledge stemmed from judicial proceedings without any extrajudicial source of bias. The court granted the motion, holding that the parties formed a complete, enforceable oral agreement with mutual assent on February 17, 2011, as confirmed by counsel's affidavit, contemporaneous notes, and the court's own records canceling the trial.
This case involves a discovery dispute in Mezu v. Morgan State University, where the plaintiff sought production of confidential personnel and FMLA-related documents from the defendant university. The court had previously ordered that the documents could be inspected at defense counsel's office, but the parties disagreed on the reasonable cost for copying and shipping them to the plaintiff's counsel. The court denied the plaintiff's motion to compel production at a lower cost, ruling that the defendant's reduced rate of $0.13 per page totaling $730.08 was reasonable, as it accounted for confidentiality requirements under Maryland law, and there was no evidence supporting the plaintiff's claim of inability to afford it. The plaintiff must pay this amount plus shipping if she wishes to obtain the copies.
This case concerns a discovery dispute in which plaintiff Patrick Richardson sought production of his ex-wife Sherri Richardson's file from defendant SARC, a sexual assault and spouse abuse resource center, and related individual defendants. Defendants asserted psychotherapist-patient privilege for most of the documents and attorney-client privilege for a subset, submitting the file for in camera review. The court held that the psychotherapist-patient privilege protects confidential communications and treatment notes even when provided by unlicensed counselors under the supervision of licensed professionals, that the attorney-client privilege applies to the relevant pages, and that neither privilege was waived by limited disclosures or by putting mental condition at issue. The court ordered production only of the non-privileged pages that were responsive to the requests.
In Kennedy v. Villa St. Catherine's, Inc., a former geriatric nursing assistant at a religious nursing center sued her employer under Title VII, alleging religious harassment, retaliatory discharge, and discriminatory discharge after her supervisor commented on her religious attire (long skirts and head covering as a member of the Church of the Brethren) and she was later terminated. The defendant moved for summary judgment, arguing that Title VII's religious organization exemption under 42 U.S.C. § 2000e-1(a) barred the claims. The plaintiff conceded the exemption applied to the discriminatory discharge count but contended it did not extend to harassment or retaliation. The court granted the motion in part and denied it in part, analyzing the exemption's scope through the statute's text, legislative history from 1964 and 1972 amendments, and precedents to determine its application to the various claims.
In United States v. Moradi, the defendant was charged by superseding misdemeanor information with simple assault on an aircraft under 18 U.S.C. § 113(a)(5) and 49 U.S.C. §§ 46506(1) and 46501, after an incident during a flight. The defendant moved to dismiss, arguing lack of federal jurisdiction because the plane was in state airspace (not 'out of the jurisdiction of any particular State' as required for special maritime and territorial jurisdiction under 18 U.S.C. § 7(5)). The court denied the motion, convicted the defendant of simple assault following a bench trial, and held that Congress created a distinct 'special aircraft jurisdiction' that permits federal prosecution of such offenses regardless of whether the aircraft is over state territory. This separate jurisdictional basis, enacted in title 49, does not incorporate the geographic limitations of 18 U.S.C. § 7.
This case arose from a prior commercial loan default action that the parties settled in 2007 with an agreement requiring defendants to pay Corsair $5 million in installments. After defendants missed payments, the parties amended the agreement in 2008 to extend deadlines, add interim payments, and grant Corsair a security interest in a patent held by defendant John Hildreth as collateral, with conditions on using the patent for other financing. When defendants again failed to pay or provide required lender commitment documents, Corsair sued for breach and sought to enforce the security interest. The court granted summary judgment in part to Corsair on liability for the payment default and enforceability of the patent security interest under Maryland's Article 9, while denying it in part on the full amount of damages sought.
