ABDUL-AZIZ v. HICKS

CourtDistrict Court, D. New Jersey
DecidedAugust 28, 2025
Docket2:20-cv-10265
StatusUnknown

This text of ABDUL-AZIZ v. HICKS (ABDUL-AZIZ v. HICKS) is published on Counsel Stack Legal Research, covering District Court, D. New Jersey primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
ABDUL-AZIZ v. HICKS, (D.N.J. 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY Chambers of Martin Luther King Jr. Federal André M. Espinosa Bldg. & U.S. Courthouse United States Magistrate Judge 50 Walnut Street, Room 2037 Newark, NJ 07102 (973)645-3827 August 28, 2025 To: Sharob Abdul-Aziz, Pro Se #264368-695922b Northern State Prison 168 Frontage Road Newark, NJ 07114 All counsel of record LETTER OPINION AND ORDER RE: Sharob Abdul-Aziz v. Hicks, et al. Civil Action No. 20-10265 (SDW)(AME) Dear Litigants: The Court has received and reviewed the letter dated March 28, 2025, filed by Plaintiff Sharob Abdul-Aziz (“Plaintiff”), containing documents entitled “Motion for Disclosures Per 28 U.S.C. § 455 & ABA Code, Section § 3(E), Issued to: U.S. District Judge Susan D. Wigenton” and “Motion for Disclosures Per 28 U.S.C. § 455 & ABA Code, Section § 3(E), Issued to: U.S. Magistrate Judge Andre M. Espinosa”. [See D.E. 128]. Plaintiff recites subsection (a) of 28 U.S.C. § 455 and, under a heading titled “ABA Code Section § 3(E),” provides “a Judge is REQUIRED to disclose on the record information that the Judge believes the parties or their Lawyers might consider relevant to the question of disqualification . . .” [Id.]. Plaintiff also requests “disclosures” from certain persons at the “New Jersey Department of Corrections”; “Law Firm: Riker Danzig, LLP”; “Law Firm: Norris McLaughlin, P.A.”; and “Rutgers, State University of New Jersey.” [Id.]. The Court also has also reviewed the June 5, 2025 letter in opposition filed by Defendants the New Jersey Department of Corrections, Justin Kemps, and Thomas Meades. [D.E. 147]. Defendants assert that Plaintiff does not clearly state the relief he seeks, but that, in any event, there is no basis for disqualification under either 28 U.S.C. § 455 or ABA Code, Section § 3(E). Defendants also argue there is no legal or factual basis for Plaintiff’s request for information pertaining to executives and employees of the DOC; the lawyers, clerks, and interns at the law firms specified; or the persons affiliated with Defendant Rutgers, The State University of New Jersey. Defendants provide that this information is overbroad and unduly burdensome under Federal Rule of Civil Procedure 26(b). Defendant Barrington Lynch, M.D. also filed a June 5, 2025 letter, joining in the opposition filed by the New Jersey Department of Corrections, Justin Kemps, and Thomas Meades. [D.E. 148]. The Court agrees with Defendants that it is unclear whether Plaintiff requests recusal of both the District Judge and the Magistrate Judge or merely requests the disclosures Plaintiff specifies. Mindful that “[c]ourts liberally construe documents filed by pro se plaintiffs,” and hold those “filings to less stringent standards than those drafted by attorneys.” Wallwork v. Horizon Blue Cross, No. 16-7095, 2017 WL 3208350, at *2 (D.N.J. July 27, 2017) (citing Erickson v. Pardus, 551 U.S. 89, 94 (2007)), the Court construes Plaintiff’s letter as motions for recusal pursuant to 28 U.S.C. § 455. As an initial matter, Plaintiff’s motions must be denied for failure to comply with this Court’s Civil Case Management Order.1 Specifically, Section 4 of that Order provides that “[o]ther than motions filed under Federal Rule of Civil Procedure 12, motions to remand within the time provided by 28 U.S.C. § 1447(c), and motions expressly permitted by this Case Management Order, formal motions shall not be filed without prior leave from this Court.” Plaintiff did not seek leave to files these motions and they must be denied for that failure to comply with required procedure. In any event, even if Plaintiff were granted leave to file these motions, insofar as Plaintiff seeks recusal of the Magistrate Judge assigned to this action, his request must be denied on the merits.2 Under 28 U.S.C. § 455(a), “any justice, judge, or magistrate judge of the United States shall disqualify himself in any proceeding in which his impartiality might reasonably be questioned.” Section 455(b) provides that such judge “shall also disqualify himself ... [w]here he has a personal bias or prejudice concerning a party, or personal knowledge of disputed evidentiary facts concerning the proceeding.” 28 U.S.C. § 455(b)(1). “Recusal is required ‘if a reasonable person, knowing all the circumstances, would expect that the judge would have actual knowledge’ of his or her interest or bias in a case.” Foster v. Holiday Hosp. Franchising, LLC, No. 24-10031, 2025 WL 2267978, at *5 (D.N.J. Aug. 8, 2025) (quoting Liljeberg v. Health Services Acquisition Corp., 486 U.S. 847, 860 (1988), and In re Kensington Intern. Ltd., 368 F.3d 289, 301 (3d Cir. 2004)). “In making this determination, courts must consider how the facts would appear to a ‘well- informed, thoughtful and objective observer, rather than the hypersensitive, cynical, and suspicious person.’” Foster, 2025 WL 2267978, at *5 (quoting United States v. Jordan, 49 F.3d 152, 156 (5th Cir. 1995)). “A recusal motion must be based on objective facts, not mere possibilities and unsubstantiated allegations.” Foster, 2025 WL 2267978, at *5 (quoting United States v. Jacobs, 311 F. App'x 535, 537 (3d Cir. 2008)) (internal quotations omitted). Here, Plaintiff’s request for recusal by the Magistrate Judge must be denied under both subsections (a) and (b) of 28 U.S.C. § 455. Plaintiff appears to assert “[a] Judge’s recusal is 1 See https://www.njd.uscourts.gov/sites/njd/files/JudgeEspinosa_CIvil_Case_Mgmt_Order_Final%204- 26-21.pdf, and hereby attached as Exhibit A. 2 This Court’s denial of Plaintiff’s recusal motion concerning the District Judge is based on his procedural failure only and is without prejudice. While Plaintiff offers no substantive basis for the District Judge to recuse, this Court must defer to the District Court’s merits evaluation here or in any properly filed motion. required due to: ‘Employment Interest’, ‘Personal Relationship’s’, ‘Financial Interest’, ‘Judge’s Relatives’, ‘LAW CLERKS” and/or “Judge’s Prior Affiliations’.” However, Plaintiff provides no facts, evidence, or arguments that could serve as a basis for recusal under this statute, nor can the Court think of any facts, evidence, or arguments that would support any assertion that the Magistrate Judge would be impartial, have “personal knowledge of disputed evidentiary facts concerning the proceeding,” or have a “personal bias or prejudice” concerning any party. Furthermore, the Court finds Plaintiff’s reference to “ABA Code, Section § 3(E)” to be unclear.

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Related

United States v. Jordan
49 F.3d 152 (Fifth Circuit, 1995)
Liljeberg v. Health Services Acquisition Corp.
486 U.S. 847 (Supreme Court, 1988)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
United States v. Jacobs
311 F. App'x 535 (Third Circuit, 2008)

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Bluebook (online)
ABDUL-AZIZ v. HICKS, Counsel Stack Legal Research, https://law.counselstack.com/opinion/abdul-aziz-v-hicks-njd-2025.