History
  • No items yet
midpage
Scofield v. Guillard
3:22-cv-00521
D. Idaho
Jun 17, 2025
Read the full case

Background

  • Rebecca Scofield filed suit against Ashley Guillard in December 2022.
  • Both parties consented to magistrate judge jurisdiction in April 2023, as allowed under 28 U.S.C. § 636(c).
  • Guillard later sought reassignment to a U.S. District Judge, which was denied for lack of extraordinary circumstances and to prevent judge-shopping after an adverse ruling.
  • Guillard moved for reconsideration of summary judgment, arguing that newly discovered evidence supported her position; the motion was denied as the evidence did not alter the outcome.
  • Guillard subsequently filed formal objections to the magistrate's May 30, 2025, order, seeking review by a district judge.
  • The court concluded that such objections were procedurally improper where parties have consented to magistrate judge jurisdiction; any appeal must be made directly to the Ninth Circuit after final judgment.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Jurisdiction to rule (post-consent) Consent remains, Magistrate Judge has authority Reassignment to District Judge appropriate Magistrate Judge retains authority post-consent
Standard for withdrawing consent Extraordinary circumstances/good cause required Recent adverse rulings justify reassignment No extraordinary circumstances found; consent stands
Reconsideration of partial summary judgment New evidence does not change result Newly discovered evidence justifies reconsideration Motion denied; evidence not outcome-determinative
Procedural propriety of objections to magistrate's order Appeal directly to Ninth Circuit required District judge can review/overturn magistrate's order District judge review is not permitted post-consent; only direct appeal allowed

Key Cases Cited

  • Branch v. Umphenour, 936 F.3d 994 (9th Cir. 2019) (only a district judge may rule on motions to withdraw consent to magistrate judge jurisdiction; extraordinary circumstances required)
  • CPC Patent Tech. Pty Ltd. v. Apple, Inc., 34 F.4th 801 (9th Cir. 2022) (if parties consent to magistrate judge, appeals from their judgments go directly to the appropriate court of appeals)
Read the full case

Case Details

Case Name: Scofield v. Guillard
Court Name: District Court, D. Idaho
Date Published: Jun 17, 2025
Citation: 3:22-cv-00521
Docket Number: 3:22-cv-00521
Court Abbreviation: D. Idaho