Scofield v. Guillard
3:22-cv-00521
D. IdahoJun 17, 2025Background
- 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)
