Commercial Litigation and Arbitration

Reasonable Application of Governing Legal Standard to the Facts Satisfies Abuse-of-Discretion Standard

Doe v. Elmbrook School Dist., 658 F.3d 710 (7th Cir. 2011):

"An abuse of discretion occurs if the district court reaches erroneous conclusions of law or premises its holding on a clearly erroneous assessment of the evidence." Gastineau v. Wright, 592 F.3d 747, 748 (7th Cir. 2010) (internal quotation marks omitted). In Pruitt v. Mote, 503 F.3d 647 (7th Cir. 2007) (en banc), we explained that an abuse of discretion occurs only if "(1) the record contains no evidence upon which the court could have rationally based its decision; (2) the decision is based on an erroneous conclusion of law; (3) the decision is based on clearly erroneous factual findings; or (4) the decision clearly appears arbitrary." Id. at 658 (quotation marks omitted). In situations such as the one before us — an application of a governing legal framework to the facts — if the district court "applied the correct legal standard and reached a reasonable decision based on facts supported by the record," its decision will stand. Id.

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