William Edgar Lewis et al. v. Richard Keuerleber et al.

Summary

The United States District Court for the Middle District of Pennsylvania denied the plaintiffs’ post-judgment motions challenging the court’s jurisdiction and consent to magistrate judge jurisdiction. The court held that the plaintiffs’ written consent was valid, that the remaining defendants had consented expressly or through their conduct, and that the motions were untimely and unsupported by good cause or extraordinary circumstances. The clerk was directed to close the case.

Holdings

1. Consent to magistrate judge jurisdiction under 28 U.S.C. § 636(c) need not always be express; it may be inferred from a party's conduct during litigation.
2. Withdrawal of consent to magistrate judge jurisdiction is not an absolute right; after referral, withdrawal requires good cause or extraordinary circumstances under 28 U.S.C. § 636(c)(4), and a timely motion.
3. A party's dissatisfaction with a magistrate judge's substantive rulings does not establish good cause or extraordinary circumstances for withdrawing consent or vacating the reference.
4. The plaintiffs' written consent was not judge-specific and remained valid after reassignment from one magistrate judge to another.

Questions Presented

1. Whether plaintiffs could withdraw or invalidate their consent to magistrate judge jurisdiction after judgment based on alleged delay, dissatisfaction with the magistrate judge's rulings, or a purported belief that consent was limited to a particular magistrate judge.
2. Whether magistrate judge jurisdiction was lacking because two defendants initially had not filed express written consents, despite their litigation conduct implying consent and their later filing express written consents.
3. Whether plaintiffs' post-judgment jurisdictional motions demonstrated good cause or extraordinary circumstances warranting withdrawal of the reference under 28 U.S.C. § 636(c)(4).

Disposition

dismissed