Hamlet Garcia, II v. Angelica Cruz

CourtCourt of Appeals for the Third Circuit
DecidedSeptember 17, 2025
Docket25-1617
StatusUnpublished

This text of Hamlet Garcia, II v. Angelica Cruz (Hamlet Garcia, II v. Angelica Cruz) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hamlet Garcia, II v. Angelica Cruz, (3d Cir. 2025).

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT ___________

No. 25-1617 __________

HAMLET GARCIA II, Appellant

v.

ANGELICA M. CRUZ, A [Wo] Man, Acting as “Owner” for “Lady Tint LLC,” et Alia ____________________________________

On Appeal from the United States District Court for the Eastern District of Pennsylvania (D.C. Civil Action No. 2:25-cv-00440) District Judge: Honorable Joshua D. Wolson ____________________________________

Submitted Pursuant to Third Circuit LAR 34.1(a) on August 1, 2025

Before: KRAUSE, PHIPPS, and ROTH, Circuit Judges

(Opinion filed: September 17, 2025) ___________

OPINION* ___________

* This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not constitute binding precedent. PER CURIAM

Pro se appellant Hamlet Garcia II appeals the District Court’s denial of his recusal

motion and reconsideration thereof, dismissal of his complaint, and denial of various

motions. We will affirm the District Court’s judgment.

I.

Garcia filed a civil action against Angelica Cruz in her capacity as owner of Lady

Tint LLC, a car-window-tinting company. Garcia alleged a conspiracy in restraint of

trade in violation of Section 1 of the Sherman Act, see 15 U.S.C. § 1, as well as state law

claims. According to the complaint, Garcia collaborated with Cruz to expand Lady Tint

LLC. But Cruz “unlawfully appropriated [Garcia’s] proprietary business methodologies

and strategies,” which “distorted the local market,” and Cruz secured “an unfair edge that

would not have been attainable absent [Garcia’s] intellectual contributions.” Eventually,

Garcia started his own tinting business, but Cruz “continued to unlawfully retain [his]

proprietary interests.” Cruz also “orchestrated a scheme to defraud” Garcia, in which she

authorized withdrawals for employees and contractors for work never performed,

authorized payments not reflected in the payroll, made unauthorized transactions on

Garcia’s company credit card, and diverted equipment for her own personal use.

Shortly after filing the complaint, Garcia moved under 28 U.S.C. § 455 for the

recusal or disqualification of the assigned District Judge. He asserted that the District

Judge was politically motivated, and biased against him, as shown by the District Judge’s

2 dismissal of his requests to be addressed as “Lord” or “King,” determination in a

different lawsuit that his claims were frivolous, and application of procedural rules.

Garcia cited various rulings from other cases that he believed cast doubt on the District

Judge’s impartiality. The District Court denied the motion. It also denied Garcia’s

motion to proceed in forma pauperis (IFP), without prejudice, for lack of sufficient

information.

Meanwhile, Garcia moved for reconsideration of the recusal motion and for relief

from the judgment, filed another IFP application, and filed various other motions. The

District Court declined to revisit the recusal issue, and it granted Garcia’s IFP motion. It

screened the complaint under 28 U.S.C. § 1915(e)(2)(B), determining that Garcia failed

to state a plausible federal antitrust claim. The District Court dismissed the antitrust

claim with prejudice, reasoning that an amended pleading would be futile; dismissed the

state law claims without prejudice for lack of subject matter jurisdiction; and denied

Garcia’s pending motions as moot. Garcia appealed.

II.

We have jurisdiction under 28 U.S.C. § 1291. We review the District Court’s

denial of the recusal and reconsideration motions for abuse of discretion. See Jones v.

Pittsburgh Nat’l Corp., 899 F.2d 1350, 1356 (3d Cir. 1990) (recusal); Gibson v. State

Farm Mut. Auto. Ins. Co., 994 F.3d 182, 186 (3d Cir. 2021) (reconsideration); see also

BLOM Bank SAL v. Honickman, 605 U.S. ___, 145 S. Ct. 1612, 1622 (2025) (citation

3 omitted) (“District courts’ Rule 60(b) rulings are reviewed ‘only for abuse of

discretion.’”). We review the District Court’s dismissal under 28 U.S.C.

§ 1915(e)(2)(B)(ii) de novo, see Allah v. Seiverling, 229 F.3d 220, 223 (3d Cir. 2000),

and the decision to dismiss without granting leave to amend for abuse of discretion,

LabMD Inc. v. Boback, 47 F.4th 164, 192 (3d Cir. 2022).

III.

The District Court did not abuse its discretion by denying the recusal motion.

Garcia’s motion offered no facts suggesting that the District Judge’s “impartiality might

reasonably be questioned,” or that the District Judge had any “personal bias or prejudice”

toward Garcia. See 28 U.S.C. § 455(a), (b)(1). Many of Garcia’s concerns were based

on the District Judge’s prior rulings and applications of procedural requirements. But “a

party’s displeasure with legal rulings does not form an adequate basis for recusal.”

Securacomm Consulting, Inc. v. Securacom Inc., 224 F.3d 273, 278 (3d Cir. 2000). And

Garcia’s dissatisfaction with the District Judge’s word choice and “dismissive tone” did

not establish bias sufficient to mandate recusal. See Liteky v. United States, 510 U.S.

540, 555–56 (1994). Further, Garcia offered no facts fairly suggesting that the District

Judge was politically influenced in this matter. See United States v. Martorano, 866 F.2d

62, 68 (3d Cir. 1989) (stating that a recusal motion must be based on “objective facts,”

not mere “possibilities” and “unsubstantiated allegations”).

4 Garcia argues that the District Court misstated the record, further supporting that

the District Judge is biased against him. It appears that Garcia is referring to the District

Court’s note that Garcia did not submit a proper declaration under penalty of perjury with

his IFP motion. But the District Court dismissed the IFP motion without prejudice, gave

Garcia an opportunity to provide additional information, and ultimately granted the IFP

motion. These facts do not reflect judicial bias, and no reasonable person would question

the District Judge’s impartiality based on this ruling. See In re Kensington Int’l Ltd., 368

F.3d 289, 301–02 (3d Cir. 2004).1

We also discern no error in the District Court’s dismissal of Garcia’s antitrust

claim with prejudice. Garcia failed to plead sufficient facts demonstrating a conspiracy

to restrain trade unreasonably in violation of the Sherman Act. See In re Baby Food

Antitrust Litig., 166 F.3d 112, 117–18 (3d Cir. 1999). Notwithstanding Garcia’s broad

conclusion that Cruz’s scheme distorted the market and significantly affected interstate

commerce, Garcia’s pleaded facts germane to his Sherman Act claim concerned only

Cruz’s business and his.

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Securacomm Consulting, Inc. v. Securacom Inc.
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