Game of Thrones Night King storyline gets torched by federal judge

Yep, that's a White Walker marching through a ruling from the US Court of Appeals for the 9th Circuit.

Leslie Katz Former Culture Editor
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Leslie Katz
2 min read

"My fellow White Walkers, see Cal. Prob. Code § 16050."


A federal appeals court's opinion on Lindie Banks v. Northern Trust Corp. is -- as one would expect from a case charging breaches of fiduciary duties -- full of references to assets, investments and irrevocable trusts. Naturally, the Night King from Game of Thrones also makes a showing. 

In the opinion filed July 5, Judge John B. Owens writes that the US Court of Appeals for the 9th Circuit won't discard a prior legal precedent "the way that Game of Thrones rendered the entire Night King storyline meaningless in its final season." 

"Goddammit, now I'm going to have to watch Game of Thrones just to be able to do my research? Thanks for nothing, Ninth Circuit," Ann Lipton, a professor of business and securities at Tulane Law School, tweeted the day the opinion was filed. 

For those who didn't watch the final season of the HBO hit, Arya Stark dropped the Night King with a blade to the heart halfway through the final season. Miffed fans complained the White Walker threat had been built up too much and for too long over the course of the series for it all to end so unceremoniously.

Owens mentions the supreme leader of the White Walkers in the context of two prior cases, Chadbourne & Parke LLP v. Troice and Merrill Lynch, Pierce, Fenner & Smith, Inc. v. Dabit. The 9th Circuit cites both in ruling in favor of the plaintiff in an appeal of a district court opinion centering on an alleged violation of state law. 

The defendant "would like us to read Dabit without considering its clarification in Troice. But we will not render Troice meaningless the way that Game of Thrones rendered the entire Night King storyline meaningless in its final season," reads page 15 of the opinion. 

The 9th Circuit didn't immediately respond to a request for comment on whether Owens signed that famous petition calling for a Game of Thrones season 8 redo -- or what he thinks of know-it-all Bran ruling the kingdom. 

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This isn't the first time Owens, an Obama appointee to the federal judiciary, has dropped a Game of Thrones reference into an opinion, as Above the Law notes.  

In the 9th Circuit case Flores v. City of San Gabriel, Owens noted that the appeals court's interpretation of a particular point was coming "very close to a qyburnian resurrection of [a rejected case law] standard (emphasis added)."

Qyburn is the disgraced unethical former maester and former hand to Queen Cersei who's killed by his own creation, the Mountain, in season 8, episode 5. The Qyburnian resurrection refers to him zombie-fying The Mountain, which seems to mean rejected case law standards are better left dead.

Fortunately, a Game of Thrones prequel's coming sometime in the next couple of years, which should give Owens plenty of new colorful material. 

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Originally published July 9, 1:46 p.m. PT.