Judicial data via CourtListener (Free Law Project). Social links via Wikidata.
Affiliations
District Court, D. Maine — appointed by George H.W. Bush
Party: Republican →Degree, Harvard UniversityJ.D., Harvard UniversityJD, Harvard University
Decision levers
AI-measured from their own opinions — each lever cites its cases
PurposivismTextualism
In United States v. Murdock the court treated the antique-firearm exception as an affirmative defense that the defendant must raise, following the statutory text and structure rather than policy considerations. United States v. Murdock ↗
Willing to revisit precedentStrong stare decisis
The opinions repeatedly apply settled procedural doctrines, such as the limits on post-verdict juror testimony in United States v. Enzinger and the exclusionary-rule attenuation analysis in United States v. Thomas, without questioning their continuing validity. United States v. Thomas ↗ United States v. Enzinger ↗
Deference to government powerSkepticism of government power
Motions to suppress evidence were denied in United States v. Taylor and United States v. Thomas, allowing the government to use the seized materials after finding that Fourth Amendment or procedural concerns did not require exclusion. United States v. Taylor ↗ United States v. Thomas ↗
Judicial activismJudicial restraint
The court consistently declined to expand remedies or revisit verdicts, as in denying a new trial in United States v. Enzinger and certifying an unsettled state-law privilege question in Bradbury v. GMAC Mortgage rather than deciding it itself. United States v. Enzinger ↗ Bradbury v. GMAC Mortgage, LLC ↗
In this 2011 federal criminal case, the defendant moved to suppress a DNA profile that had been obtained in 2005 through a grand jury subpoena issued in connection with an unrelated investigation into a threatening letter containing white powder. The court held that any potential deficiencies in the 2005 subpoena process did not require exclusion of the DNA profile under the exclusionary rule when it was later used to support warrants and charges for separate threatening letters mailed in 2010. The decision rested on the principle that the exclusionary rule does not apply to bar evidence from a prior, uncharged matter in a new and unrelated prosecution, even assuming the original subpoena raised Fourth Amendment concerns regarding compelled production of DNA.
Current and former FedEx delivery drivers in Maine sued the company under the Fair Labor Standards Act, alleging they were misclassified as independent contractors rather than employees and therefore denied overtime pay for hours over 40 per week. The plaintiffs moved for conditional certification of a collective action covering Maine drivers who operate trucks under 10,001 pounds on single full-time routes. The court granted the motion, finding that the drivers had made the modest factual showing required at the initial stage by presenting evidence of similar job duties, uniform requirements, common per-package pay policies under Operator Agreements, and a shared alleged misclassification. This showing was sufficient to send notice to potential opt-in plaintiffs, with the economic-realities analysis deferred until the second stage after discovery.
In Lynch v. Christie, a Maine chiropractor sued a former patient for defamation and wrongful use of civil proceedings after she accused him of sexual assault during treatment, reported the claims to police and a licensing board, filed a federal civil lawsuit that she later dismissed with prejudice, and later posted anonymous accusations on a website and social media that eventually identified him. The defendant moved to dismiss under Maine’s anti-SLAPP statute, arguing her statements and lawsuit were protected petitioning activity, and also under Rule 12(b)(6) for failure to state a claim. The court denied both motions, finding that the plaintiff had made a strong showing the prior lawsuit and statements lacked reasonable factual support and caused him actual injury, and that the amended complaint plausibly alleged the elements of the tort claims under Maine law.
The case involved a defendant indicted and convicted by a jury of being a felon in possession of a firearm under 18 U.S.C. §§ 922(g)(1) and 924(a)(2). The defendant renewed a motion for acquittal, arguing that the government failed to prove the firearms were not antiques excluded from the statutory definition of firearm. The court denied the motion, holding that the antique firearm exception under 18 U.S.C. § 921(a)(16) is an affirmative defense that the defendant must timely raise and support with evidence, rather than an element of the offense that the government must disprove in every prosecution. The court noted that the defendant presented no such evidence at trial and raised the issue only after the evidentiary record closed. It aligned with decisions from other circuits on this allocation of burdens.
The case involved a dispute between United Systems Access Telecom, Inc., a debtor in bankruptcy proceedings operating as a Competitive Local Exchange Carrier, and FairPoint, an Incumbent Local Exchange Carrier, over amounts owed under agreements including the Interconnection Agreement and Wholesale Advantage Services Agreement, particularly whether Performance Assurance Plan penalties could offset debts. The debtor sought to withdraw the reference from the Bankruptcy Court to the District Court, arguing that the matter required interpretation of federal telecommunications law under the Telecommunications Act of 1996. The court granted the motions to withdraw the reference, holding that adjudication would require consideration of federal law regulating interstate commerce, which mandates withdrawal under 28 U.S.C. § 157(d) given the FCC's extensive regulation of telecommunications and FairPoint's commitments under Section 271 approvals.
In United States v. Enzinger, the defendant was convicted by a jury after a brief criminal trial on charges not detailed in the opinion, and later moved for a new trial based on a post-verdict letter from one juror who claimed to have misunderstood the unanimity requirement and gone along with the guilty verdict rather than holding out. The court denied the motion to set aside the verdict. The ruling followed the longstanding rule against inquiring into jury deliberations except in narrow circumstances under Federal Rule of Evidence 606(b), such as extraneous prejudicial information, outside influences, or errors in recording the verdict on the form, none of which were present; a juror's misunderstanding of instructions does not qualify as an exception, even under the First Circuit's limited constitutional exception for racial bias. The judge noted that the instructions clearly required each juror to decide individually and that the verdict was confirmed by all jurors in open court without objection.
