U.S. District Judge Fern Smith may have left the bench two weeks ago, but that didn’t stop her from rebuking San Francisco plaintiffs attorney Dennis Cunningham in a Wednesday order dismissing most of a civil rights case filed by the family of Eugene “Bear” Lincoln and others.

Now being handed off to other judges are most of Smith’s cases, including Lincoln v. Tuso, 96-1297, which involves claims against law enforcement agencies stemming from a manhunt at a Northern California Indian reservation. But Smith, in her order, said she wanted to resolve the summary judgment motion in Lincoln before moving to Washington, D.C., to take over the Federal Judicial Center.