LIVINGSTON v. CITY OF ENGLEWOOD NEW JERSEY

District Court, D. New Jersey·Decided September 11, 2025·No. 2:24-cv-06396·Unknown

Opinion

NOT FOR PUBLICATION

UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY

BRADLEY TALMADGE LIVINGSTON,

Plaintiff, Civil Action No. 24-cv-06396 v. OPINION AND ORDER CITY OF ENGLEWOOD NEW JERSEY, September 11, 2025 Defendant. SEMPER, District Judge. The current matter comes before the Court on pro se Plaintiff Bradley Livingston’s (“Plaintiff”) motion for recusal of the Undersigned. (ECF 47, “Motion” or “Pl. Mot.”). Defendant City of Englewood New Jersey (“Defendant” or “Englewood”) opposed the motion. (ECF 54, “Opp.”). Plaintiff filed a reply. (ECF 57, “Reply.”). The Court has decided this motion upon the submissions of the parties, without oral argument, pursuant to Federal Rule of Civil Procedure 78 and Local Civil Rule 78.1. For the reasons stated below, Plaintiff’s motion for recusal is DENIED. I. FACTUAL BACKGROUND AND PROCEDURAL HISTORY This matter arises from pro se Plaintiff’s grievances against Englewood’s police department for allegedly failing to enforce federal immigration laws against Plaintiff’s ex-wife. (See ECF 1 (Complaint); ECF 46 (First Amended Complaint).) Plaintiff filed this case on May 22, 2024. (ECF 1.) On January 8, 2025, this Court granted Defendant’s Motion to Dismiss Plaintiff’s Complaint. (ECF 44, ECF 45.) That same day, Plaintiff filed an Amended Complaint (ECF 46) and also moved to recuse the Undersigned. (ECF 47.) Plaintiff is a frequent litigant in this District. (See ECF 76 at 1-2.). He has sought judicial recusal in a number of the matters in which he is Plaintiff. (Id. at 2.). In this matter, Plaintiff has separately sought the recusal of Magistrate Judge Stacey Adams, alleging that Judge Adams was “biased and prejudiced” against him. (ECF 42 at 1.). Plaintiff’s motion to recuse Judge Adams was

denied on April 2, 2025. (ECF 76.). II. LEGAL STANDARD Recusal decisions are within the “sound discretion” of the trial court judge. United States v. Wilensky, 757 F.2d 594, 599-600 (3d Cir. 1985). The two federal statutes which address judicial recusal are 28 U.S.C. §§ 144 and 455. Clauso v. Bonds, No. 18-12217, 2022 WL 92803, at *1 (D.N.J. Jan. 10, 2022). Pursuant to 28 U.S.C. § 144, recusal is required where “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[.]” 28 U.S.C. § 144. A “‘substantial burden is imposed on the party [seeking recusal under § 144] to

demonstrate that the judge is not impartial.’” Reeves v. Hemsley, No. 18-14061, 2019 WL 2560133, at *1 (D.N.J. June 21, 2019) (quoting Frolow v. Wilson Sporting Goods Co., No. 05- 4813, 2011 WL 1337513, at *2 (D.N.J. Apr. 7, 2011)). Under § 455(a), recusal is required where a judge’s “impartiality might reasonably be questioned.” 28 U.S.C. § 455(a). “‘The test for recusal under § 455(a) is whether a reasonable person, with knowledge of all the facts, would conclude that the judge’s impartiality might reasonably be questioned.’” Allen v. Parkland Sch. Dist., 230 F. App’x 189, 193 (3d Cir. 2007) (quoting In re Kensington, 353 F.3d 211, 220 (3d Cir. 2003)). A party moving pursuant to § 455(a) “need not show actual bias.” Karteron v. Garland, No. 22-00539, 2023 WL 2238066, at *2 (D.N.J. Feb. 24, 2023) (citing In re Kensington Int’l Ltd., 368 F.3d 289, 302 (3d Cir. 2004)). Rather, the movant only needs to demonstrate an “objective appearance of bias, rather than bias-in-fact.” United States v. Nobel, 696 F.2d 231, 235 (3d Cir. 1982). Pursuant to § 455(b)(1), a judge must recuse 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). “Under § 455(b)(1), a movant must show ‘a favorable or unfavorable disposition or opinion that is somehow wrongful or inappropriate, either because it is undeserved, or because it rests upon knowledge that the subject ought not to possess…or because it is excessive in degree.’” Karteron, 2023 WL 2238066, at *2 (quoting Liteky v. United States, 510 U.S. 540, 550 (1994)). Unlike § 455(a), § 455(b)(1) also requires a showing of “actual bias or prejudice held.” Id. (citing United States v. Sciarra, 851 F.2d 621, 635 (3d Cir. 1988) (“Although subsection (a) requires only the objective appearance of bias, subsection (b)(1) requires bias-in- fact.”)). The Supreme Court has explained that “judicial rulings alone almost never constitute a

valid basis for a bias or partiality [recusal] motion,” and are instead “proper grounds for appeal, not for recusal.” Liteky 510 U.S. at 555; see also Securacomm Consulting, Inc. v. Securacom Inc., 224 F.3d 273, 278 (3d Cir. 2000) (“[w]e have repeatedly stated that a party’s displeasure with legal rulings does not form an adequate basis for recusal…”). III. ANALYSIS In the instant Motion (ECF 47), Plaintiff seeks the recusal of the Undersigned pursuant to 28 U.S.C. § 144, alleging without any support that the Undersigned is “biased and prejudiced against the plaintiff Bradley Livingston and that he is biased and prejudiced in the context of the case[.]” (Pl. Mot. at 1). Although Plaintiff references an “Affidavit of Bias and Prejudice” submitted with his Motion (id.), Plaintiff failed to file a supporting affidavit. Instead, Plaintiff included with his Motion a letter stating that the Motion is based on 28 U.S.C. § 144, and in which he repeats, verbatim, the first part of the statute. (Id. at 2). Plaintiff’s letter ends with the arguably threatening conclusion that “[t]he Bible verse that states God will punish those who persecute you

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LIVINGSTON v. CITY OF ENGLEWOOD NEW JERSEY, (D.N.J. 2025).

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