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Dismissal based on outside records

Mary Minton Eitel v. Stoll Keenon Ogden PLLC

Updated Nov 11, 2026

In brief

Where it stands
Dismissed

Petition denied.

What it’s about
Mary Eitel challenges the throwing out of her lawsuit against Stoll Keenon Ogden PLLC under a state-law time limit, saying the federal judge relied on docket entries from separate cases that neither side cited.
Who it affects
Eitel did not get Supreme Court review of her challenge to how the federal judge used records from other cases.

Summary: written with AI from the case record.

Illustration for Mary Minton Eitel, Petitioner v. Stoll Keenon Ogden PLLC
Conceptual illustration · AI-generated

What it's about

She asks whether the judge could use those records without letting her change the complaint or treating the motion as a request to decide the case based on evidence outside the complaint.

Eitel's underlying lawsuit against the law firm was dismissed under a state-law deadline.

Question presented

Whether a federal court sitting in diversity may cite to docket entries in separate proceedings, uncited by either party and extrinsic to the complaint, as the basis for dismissal of the complaint under 12(b)(6) without permitting amendment or converting the motion to one for summary judgment under Rule 56. In effect, may the federal district courts delve into the role of advocate and utilize extrinsic evidence which is neither critical to nor relied upon by a non-moving Plaintiff opposing a 12(b)(6) motion on state statute of limitations grounds without abusing discretion?

Documents

1

Docket activity

7
  • New analysis added

    Nov 11, 2026 · Court records

  • AI analysis generated: Case Briefing

    Nov 11, 2026 · Generated

  • AI analysis generated: Decision Record

    Nov 11, 2026 · Generated

  • New analysis added

    Nov 11, 2026 · Court records

  • Case data updated: summary, question_presented, generation_metadata

    Nov 11, 2026 · Court records

Show 2 more
  • Case data updated: question_presented, extraction_metadata

    Nov 11, 2026 · Court records

  • Brief added: Petition

    Sep 8, 2026 · Court records

More questions

3
What did Eitel ask the Supreme Court to review?
She asked whether a federal judge could throw out her complaint using docket entries from other cases that neither side cited, without letting her change the complaint or treating the motion as a request to decide the case using outside evidence.
Was oral argument scheduled?
No. Argument had not been scheduled when the Supreme Court denied review.
Which appeals court did the case come from?
The case came from the U.S. Court of Appeals for the Sixth Circuit.

Sources

Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.

Checked Nov 11, 2026Methodology

Court records and filings

Reporting and analysis