Joseph v. City of San Jose

CourtDistrict Court, N.D. California
DecidedNovember 30, 2022
Docket1:19-cv-01294
StatusUnknown

This text of Joseph v. City of San Jose (Joseph v. City of San Jose) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Joseph v. City of San Jose, (N.D. Cal. 2022).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 EUREKA DIVISION 7 8 RHAWN JOSEPH, Case No. 19-cv-01294-RMI

9 Plaintiff, ORDER RE: PLAINTIFF’S REQUEST 10 v. FOR RECUSAL OR DISQUALIFICATION 11 CITY OF SAN JOSE, et al., Re: Dkt. No. 156 12 Defendants.

13 14 Now pending before the court is Plaintiff’s “Demand for Voluntary Recusal” (dkt. 156), 15 pursuant to 28 U.S.C. § 455. The document is remarkably short in that it consists of only seven 16 sentences arranged into five numbered paragraphs. In essence, Plaintiff suggests – in conclusory 17 fashion and without providing any hint of detail – that the undersigned: “has consistently 18 demonstrated bias in the case”; that the undersigned has “engaged in conduct so dishonest and 19 divorced from reality [] that it shocks even other attorneys who find this behavior [] inexplicable 20 and astonishing”; that the undersigned has “consistently engaged in conduct that violates” judicial 21 ethics cannons as well as Plaintiff’s constitutional rights; that the undersigned has “interfered with 22 Plaintiff’s attempt to conduct discovery, and has bullied and treated this Plaintiff as if he is trash”; 23 that the undersigned’s “conduct is not just biased and dishonest, but malicious”; and, pursuant to § 24 455(a)(b) [sic] that the undersigned “has a legal and ethical responsibility to voluntarily recuse 25 himself from the case . . . immediately.” Pl.’s Mot. (dkt. 156) at 1. The court finds that, pursuant 26 to Federal Rule of Civil Procedure 78(b) and Civil Local Rule 7-1(b), Plaintiff’s request is suitable 27 for disposition without oral argument. For the reasons stated below, Plaintiff’s request is meritless 1 There are two federal statutes that address standards for recusal: 28 U.S.C. §§ 144 and 455. 2 While Plaintiff has only invoked §455, to give effect to liberal construction of Plaintiff’s 1-page 3 request, the undersigned will address both statutes. Generally speaking, a judge is required to 4 recuse if he or she has a personal bias or prejudice against a party. Gonzales v. Parks, 830 F.2d 5 1033, 1037 (9th Cir. 1987). A motion to disqualify under § 144 requires the party to file a legally 6 sufficient affidavit alleging facts supporting the claim that the judge is biased or prejudiced against 7 that party. See United States v. Sibla, 624 F.2d 864, 867 (9th Cir. 1980). If the affidavit is legally 8 insufficient or unsupported by a factual basis, the court must deny the motion. Id. at 868. In this 9 case, Plaintiff did not reference § 144, or submit a § 144 affidavit, or set forth anything remotely 10 resembling a factual basis; instead, Plaintiff’s motion seeking disqualification is expressly based 11 on § 455(a) and (b)(1). See Pl.’s Mot. (dkt. 156) at 1 (asserting that the undersigned should be 12 disqualified from presiding over this case due to “personal bias or prejudice concerning a party.”). 13 Accordingly, the court will address Plaintiff’s contentions under § 455. 14 In either case, “[t]he substantive standard for recusal under 28 U.S.C. § 144 and 28 U.S.C. 15 § 455 is the same: Whether a reasonable person with knowledge of all the facts would conclude 16 that the judge’s impartiality might reasonably be questioned.” United States v. McTiernan, 695 17 F.3d 882, 891 (9th Cir. 2012) (emphasis added) (quoting United States v. Hernandez, 109 F.3d 18 1450, 1453 (9th Cir. 1997) (per curiam)); see also Sibla, 624 F.2d at 867 (“The test for personal 19 bias or prejudice in section 144 is identical to that in section 455(b)(1), and the decisions 20 interpreting this language in section 144 are controlling in the interpretation of section 455(b)(1)”). 21 For present purposes, it is important to note that, “[t]he ‘reasonable person’ in this context means a 22 ‘well-informed, thoughtful observer,’ as opposed to a ‘hypersensitive or unduly suspicious 23 person.’” Clemens v. United States Dist. Court, 428 F.3d 1175, 1178 (9th Cir. 2005) (quoting In re 24 Mason, 916 F.2d 384, 385 (7th Cir. 1990)). It should also not escape mention that, as explained by 25 the Supreme Court in Liteky v. United States, 510 U.S. 540 (1994), “judicial rulings alone almost 26 never constitute a valid basis for a bias or partiality motion.” Id. at 555. The Litekey Court 27 explained that, “[i]n and of themselves (i.e., apart from surrounding comments or accompanying 1 can only in the rarest circumstances evidence the degree of favoritism or antagonism required (as 2 discussed below) when no extrajudicial source is involved.” Id. Thus, while judicial rulings are 3 almost invariably proper grounds for an appeal, they rarely constitute, by themselves, a proper 4 basis for recusal. Id. Additionally, the opinions formed by a judge on the basis of events occurring 5 in the course of the proceedings likewise do not constitute a basis for a bias or partiality motion 6 except when they display “a deep-seated favoritism or antagonism that would make fair judgment 7 impossible.” Id. Even “judicial remarks during the course of a trial that are critical or disapproving 8 of, or even hostile to, counsel, the parties, or their cases, ordinarily do not support a bias or 9 partiality challenge.” Id. However, such remarks may support such a motion “if they reveal an 10 opinion that derives from an extrajudicial source; and they will do so if they reveal such a high 11 degree of favoritism or antagonism as to make fair judgment impossible.” Id. 12 By way of example, the Litekey Court cited to Berger v. United States, 255 U.S. 22 (1921), 13 a World War I espionage case against German-American defendants wherein the trial judge had 14 remarked to the following effect: “‘One must have a very judicial mind, indeed, not [to be] 15 prejudiced against the German Americans’ because their ‘hearts are reeking with disloyalty.’” 16 Liteky, 510 U.S. at 555 (quoting Berger, 255 U.S. at 28). In this regard, the Court elaborated 17 further that mere “expressions of impatience, dissatisfaction, annoyance, and even anger, that are 18 within the bounds of what imperfect men and women, even after having been confirmed as federal 19 judges, sometimes display,” are not suitable bases for recusal or disqualification motions. Liteky, 20 510 U.S. at 555-56. Lastly, and perhaps most importantly for present purposes, it should not go 21 without mention that “[a] judge’s ordinary efforts at courtroom administration – even a stern and 22 short-tempered judge’s ordinary efforts at courtroom administration – remain immune.” Id. at 556. 23 Under these standards, Plaintiff’s motion is baseless. Indeed, the motion is patently frivolous. As 24 described below, Plaintiff’s established pattern of over-the-top reactions stemming from his 25 dissatisfaction with this court’s “ordinary efforts at courtroom administration” are not a suitable 26 basis for disqualification motions. 27 This case was filed in March of 2019. See Compl. (dkt. 1).

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Related

Berger v. United States
255 U.S. 22 (Supreme Court, 1921)
Liteky v. United States
510 U.S. 540 (Supreme Court, 1994)
Pratt v. Philbrook
109 F.3d 18 (First Circuit, 1997)
United States v. Richard R. Sibla
624 F.2d 864 (Ninth Circuit, 1980)
United States v. Steven Lynn Griffith
17 F.3d 865 (Sixth Circuit, 1994)

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Joseph v. City of San Jose, Counsel Stack Legal Research, https://law.counselstack.com/opinion/joseph-v-city-of-san-jose-cand-2022.