LaBranche v. Apple Inc.

CourtDistrict Court, E.D. Louisiana
DecidedMarch 3, 2025
Docket2:24-cv-00234
StatusUnknown

This text of LaBranche v. Apple Inc. (LaBranche v. Apple Inc.) is published on Counsel Stack Legal Research, covering District Court, E.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
LaBranche v. Apple Inc., (E.D. La. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA JAMIE LABRANCHE CIVIL ACTION VERSUS NO. 24-234 APPLE, INC., ET AL. SECTION “O” ORDER AND REASONS

Before the Court is pro se Plaintiff Jamie LaBranche’s motion1 to recuse Magistrate Judge Currault and me. Liberally construed, see Collins v. Dall. Leadership Found., 77 F.4th 327, 330 (5th Cir. 2023), LaBranche’s pro se motion asserts that recusal is required under 28 U.S.C. §§ 455(a), (b)(1), and (b)(3). This litigation arises from Jamie LaBranche’s allegation that Defendant Apple, Inc., and its CEO, Defendant Tim Cook, “fail[ed] to protect” LaBranche’s “private intel emails” from being hacked by a person with “a Chinese number.”2

According to LaBranche, his hacked email account has “classified and declassified emails from federal government agencies[.]”3 LaBranche alleges that he received emails from Apple informing him that his Apple ID had been used to sign-in to iMessage.4 LaBranche “followed [the] instructions at [the] bottom of [those] email[s],” but he was “lock[ed] out” of his account.5 LaBranche alleges that his email

1 ECF No. 26. 2 ECF No. 6 at 6–7. For readability, the Court has modified the capitalization and boldface LaBranche employs in his filings. 3 Id. at 6. 4 Id. 5 Id. account was “shut down” “about a week later[.]”6 LaBranche eventually “talked to around six Apple reps” who told him his email account “would not be reactivated.”7 According to LaBranche, “one guy named Steve” told LaBranche that “a

Chinese number was linked to [LaBranche’s] [email] account.”8 LaBranche alleges that he found that revelation “very disturbing,” because “the only person [LaBranche] ever gave [his] password to is a[n] Apple worker who helped [him]” with his email account “roughly five or six years ago.”9 LaBranche thus suspects that this “Apple worker” is “maybe selling classified docs to the Chinese.”10 Based on these allegations, LaBranche sued Apple and Cook in this Court, invoking diversity jurisdiction, 28 U.S.C. § 1332(a)(1). Magistrate Judge Currault

granted LaBranche leave to proceed in forma pauperis.11 Even with the benefit of liberal construction, it is unclear what cause(s) of action LaBranche intends to assert. What is clear, however, is that LaBranche asks for “$100,000 . . . a day starting on 12-26-2023 . . . to show [Apple and Cook] how serious this suit is.”12 In response, Apple and Cook moved to dismiss LaBranche’s complaint under Rule 12(b)(6) and 28 U.S.C. § 1915(e)(2)(B)(i).13 Apple and Cook contend that

6 Id. 7 Id. 8 Id. at 7. 9 Id. 10 Id. 11 ECF No. 8. 12 ECF No. 6 at 7. 13 ECF No. 12. LaBranche’s suit is frivolous and that LaBranche fails to state any plausible claims against them.14 LaBranche opposes.15 That motion to dismiss is pending. In connection with his opposition to that motion to dismiss, LaBranche sought

leave to file exhibits under seal.16 He asserted without explanation that the exhibits included “classified” documents. The Court denied his motion because there was “no indication that the documents are in fact classified.”17 The Court later granted LaBranche’s motion to withdraw the exhibits he had unsuccessfully sought to seal.18 Later, with the motion to dismiss still pending, LaBranche moved the Court for discovery and for leave to amend his complaint.19 Magistrate Judge Currault denied LaBranche discovery because LaBranche did not properly serve Apple and

Cook with his discovery requests, and LaBranche did not certify that he had conferred or tried to confer with Apple and Cook before filing his motion.20 And Magistrate Judge Currault denied LaBranche leave to amend his complaint to add a claim under the Computer Fraud and Abuse Act because she held that amendment was futile.21 A week after Magistrate Judge Currault denied LaBranche’s motion for leave to amend his complaint, LaBranche moved to recuse Magistrate Judge Currault and

me under 28 U.S.C. § 455.22 His liberally construed pro se motion contends that recusal is required under Subsections (a), (b)(1), and (b)(3) of 28 U.S.C. § 455.

14 ECF No. 12-1 at 1–6. 15 ECF No. 14, 22. 16 ECF No. 15. 17 ECF No. 16 at 1–2. 18 ECF No. 19. 19 ECF No. 20; ECF No. 24. 20 ECF No. 21. 21 ECF No. 25. 22 ECF No. 26. Under Subsection (a), “[a]ny justice, judge, or magistrate judge of the United States shall disqualify himself in any proceeding in which his impartiality might reasonably be questioned.” 28 U.S.C. § 455(a). “The relevant inquiry is whether a

reasonable man, were he to know all the circumstances, would harbor doubts about the judge’s impartiality.” United States v. Quintanilla, 114 F.4th 453, 468 (5th Cir. 2024) (quotation and citation omitted). Subsection (b)(1) requires a judge to “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). And Subsection (b)(3) requires disqualification “[w]here [the judge] has served in governmental employment and in such capacity participated as counsel,

adviser or material witness concerning the proceeding or expressed an opinion concerning the merits of the particular case in controversy[.]” 28 U.S.C. § 455(b)(3). In evaluating recusal, “the Supreme Court has directed [courts] to consider whether the judge’s views are ‘extrajudicial.’” Tejero v. Portfolio Recovery Assocs., L.L.C., 955 F.3d 453, 463 (5th Cir. 2020) (quoting Liteky v. United States, 510 U.S. 540, 551 (1994)). “An opinion is not extrajudicial if it was ‘formed by the judge on the

basis of facts introduced or events occurring in the course of the current proceedings, or of prior proceedings.’” Id. (quoting Liteky, 510 U.S. at 555). “Non-extrajudicial facts ‘do not constitute a basis for a bias or partiality motion unless they display a deep- seated favoritism or antagonism that would make fair judgment impossible.’” Id. (quoting Liteky, 510 U.S. at 555). “Even the presence of extrajudicial facts, without something more, does not suffice to show bias.” Id. (citing Liteky, 510 U.S. at 554). Liberally construed, LaBranche’s pro se motion raises two principal grounds for recusal under Subsections (a), (b)(1), and (b)(3) of 28 U.S.C. § 455. Neither has merit.

First, LaBranche contends that recusal is required because my service as an Assistant United States Attorney (“AUSA”) in the Eastern District of Louisiana overlapped with the service of another AUSA, Jason Bigelow, who was counsel for the Department of Defense Inspector General in a civil case LaBranche filed in 2015. See Complaint, LaBranche v. Dep’t of Defense, No. 15-CV-2280 (E.D. La. June 23, 2015), ECF No.

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Related

Liteky v. United States
510 U.S. 540 (Supreme Court, 1994)
United States v. Mmr Corp. And James B. Rutland
954 F.2d 1040 (Fifth Circuit, 1992)
United States v. Brion Randall
440 F. App'x 283 (Fifth Circuit, 2011)
Luis Tejero v. Portfolio Recovery Assoc, LL
955 F.3d 453 (Fifth Circuit, 2020)
Collins v. Dallas Ldrshp Fdn
77 F.4th 327 (Fifth Circuit, 2023)
United States v. Quintanilla
114 F.4th 453 (Fifth Circuit, 2024)

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LaBranche v. Apple Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/labranche-v-apple-inc-laed-2025.