Draper Frank Woodyard v. Judge Michael J. Hoylt

CourtDistrict Court, S.D. Alabama
DecidedFebruary 13, 2026
Docket1:25-cv-00183
StatusUnknown

This text of Draper Frank Woodyard v. Judge Michael J. Hoylt (Draper Frank Woodyard v. Judge Michael J. Hoylt) is published on Counsel Stack Legal Research, covering District Court, S.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Draper Frank Woodyard v. Judge Michael J. Hoylt, (S.D. Ala. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ALABAMA SOUTHERN DIVISION

DRAPER FRANK WOODYARD, ) ) Plaintiff, ) ) vs. ) CIV. ACT. NO. 1:25-cv-183-TFM-N ) JUDGE MICHAEL J. HOYLT, ) ) Defendant. )

MEMORANDUM OPINION AND ORDER Pending is the motion to transfer venue (Doc. 15) in which Plaintiff makes unfounded allegations against the Magistrate Judge and complains about the undersigned indicating that there is a lawsuit pending. The undersigned learned this for the first time when reviewing this case. Plaintiff did file a lawsuit on June 25, 2025. See Woodyard v. Nelson, et al., Civ. Act. No. 1:25- cv-258-RAH-BR (S.D. Ala.). The case was assigned to judges from outside the district, was dismissed on January 12, 2026 (see Docs. 8, 10) and is now on appeal (see Doc. 11). Also pending before the Court are Plaintiff’s objection to the Magistrate Judge’s order denying the motion to intercede (Docs. 17, 18, 19), the Report and Recommendation (Doc. 13), and the related objections/subsequent motions (Docs. 14, 16). Regardless, the Court will address the motion to transfer venue and address the issue in the form of a request to recuse before turning to the remainder of the review in this case. A. Recusal / Venue Motion “Two statutes govern recusal — 28 U.S.C. §§ 144 and 455.” United States v. Berger, 375 F.3d 1223, 1227 (11th Cir. 2004) (citing Hamm v. Members of Bd. of Regents of State of Fla., 708 F.2d 647, 651 (11th Cir. 1983)). 28 U.S.C. § 144 states: Whenever a party to any proceeding in a district court makes and files a timely and sufficient affidavit that the judge before whom the matter is pending has a personal bias or prejudice either against him or in favor of any adverse party, such judge shall proceed no further therein, but another judge shall be assigned to hear such proceeding.

The affidavit shall state the facts and the reasons for the belief that bias or prejudice exists, and shall be filed not less than ten days before the beginning of the term [session] at which the proceeding is to be heard, or good cause shall be shown for failure to file it within such time. A party may file only one such affidavit in any case. It shall be accompanied by a certificate of counsel of record stating that it is made in good faith.

28 U.S.C. § 144. Next, 28 U.S.C. § 455 in relevant parts state as follows: (a) Any justice, judge, or magistrate [magistrate judge] of the United States shall disqualify himself in any proceeding in which his impartiality might reasonably be questioned.

(b) He shall also disqualify himself in the following circumstances: (1) Where 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(a), (b)(1). Looking first at 28 U.S.C. § 144, it states “whenever a party . . . makes and files a timely . . . affidavit . . .” and that it further states “the affidavit . . . shall be filed not less than ten days before the beginning of the term . . . or good cause shall be shown for failure to file it within such time.” Moreover, “[a] motion for recusal based upon the appearance of partiality must be timely made when the facts upon which it relies are known. The untimeliness of such a motion is itself a basis upon which to deny it.” United States v. Siegelman, 640 F.3d 1159, 1188 (11th Cir. 2011) (citing Phillips v. Amoco Oil Co., 799 F.2d 1464, 1472 (11th Cir. 1986)). “The purpose of the rule is to ‘conserve judicial resources and prevent a litigant from waiting until an adverse decision has been handed down before moving to disqualify the judge.’” Id. (quoting Summers v. Singletary, 119 F.3d 917, 921 (11th Cir. 1997)). “[T]he standard of review for a § 455(a) motion ‘is whether an objective, disinterested, lay observer fully informed of the facts underlying the grounds on which recusal was sought would entertain a significant doubt about the judge's impartiality[.]”. United States v. Patti, 337 F.3d 1317, 1321 (11th Cir. 2003) (quoting Parker v. Connors Steel Co., 855 F.2d 1510, 1524 (11th Cir. 1988)). While doubts must be resolved in favor of recusal, United States v. Kelly, 888 F.2d 732, 745 (11th Cir. 1989), “a judge should not recuse [himself] based upon unsupported and tenuous

allegations,” Yeyille v. Miami Dade Cnty. Pub. Sch., 654 F. App’x 394, 396 (11th Cir. 2016) (quoting Giles v. Garwood, 853 F.2d 876, 878 (11th Cir. 1988)). Plaintiff’s complaints seemingly fall under the category of “adverse rulings” and general grievances of perceived unfairness. Additionally, Plaintiff failed to comply with the requirement to submit an affidavit pursuant to 28 U.S.C. § 144. His motion is slim on reasoning and support. Even reviewing the complaint in the separate lawsuit against the undersigned (which is signed though not sworn as an affidavit) and the Magistrate Judge, the Court finds that the complaints simply relate to the rulings in his various cases. He claims that we have blocked his right of access to courts because of those rulings.

“[I]t is well settled that the allegation of bias must show that the bias is personal as distinguished from judicial in nature. As a result, except where pervasive bias is shown, a judge’s rulings in the same or a related case are not a sufficient basis for recusal.” Bolin v. Story, 225 F.3d 1234, 1239 (11th Cir. 2000) (citations omitted); see also Liteky v. United States, 510 U.S. 540, 555 (1994) (citing United States v. Grinnell Corp., 384 U.S. 563, 583 (1966) (holding that a court’s “judicial rulings alone almost never” satisfy the standard for recusal)); Byrne v. Nezhat, 261 F.3d 1075, 1103 (11th Cir. 2001) (“[A]dverse rulings alone do not provide a party with a basis for holding that the court’s impartiality is in doubt.”). Moreover, when a motion for disqualification relies on other grounds, recusal is improper unless the moving party can show that the judge has “displayed deep-seated and unequivocal antagonism that would render fair judgment impossible.” Liteky, 510 U.S. at 556; see id.

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Bluebook (online)
Draper Frank Woodyard v. Judge Michael J. Hoylt, Counsel Stack Legal Research, https://law.counselstack.com/opinion/draper-frank-woodyard-v-judge-michael-j-hoylt-alsd-2026.