Butler v. Village Caregiving, LLC, 2:22-cv-04359

Plaintiffs, led by Jennifer Butler, filed a class action against Village Caregiving, LLC.
The parties notified the Court of a settlement reached "in principle."
Both sides jointly moved to refer settlement-related proceedings to Magistrate Judge Deavers, with the case reverting to Judge Marbley if the settlement failed.
The motion limited consent to the Magistrate Judge’s authority to only settlement-related matters.
The parties requested conditional or partial consent, rather than full consent to the magistrate's jurisdiction for all purposes.
The case is before the United States District Court for the Southern District of Ohio, Eastern Division.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court can grant limited consent to a magistrate judge’s jurisdiction solely for settlement proceedings	Jointly sought limited referral for settlement matters	Jointly sought limited referral for settlement matters	Conditional/limited consent not permitted under 28 U.S.C. § 636(c); motion denied without prejudice

Roell v. Withrow, 538 U.S. 580 (2003) (sets standard for magistrate judge consent under § 636(c))
Carter v. Sea Land Servs., Inc., 816 F.2d 1018 (5th Cir. 1987) (explains factors for assessing "extraordinary circumstances" to vacate magistrate referral)
Milhous v. Metro. Gov't of Nashville & Davidson Cnty., 221 F.3d 1335 (6th Cir. 2000) (dissatisfaction with magistrate’s rulings not extraordinary circumstance to vacate referral)
Moses v. Sterling Comm (Am.), Ind., 122 F. App’x 177 (6th Cir. 2005) (full authority over dispositive motions requires full consent; references cannot be conditional)